Somalia sanctions: statutory guidance
Updated 25 March 2026
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Introduction
This guidance is about the financial, director disqualification, trade and immigration sanctions imposed by The Somalia (Sanctions) (EU Exit) Regulations 2020 (‘the Regulations’).
About the Regulations
The Regulations impose sanctions both for the purpose of giving effect to the United Kingdom’s obligations under United Nations Security Council Resolutions, including:
- UNSCR 751 (1992)
- UNSCR 1844 (2008)
- UNSCR 2002 (2011)
- UNSCR 2036 (2012)
- UNSCR 2060 (2012)
- UNSCR 2093 (2013)
- UNSCR 2444 (2018)
- UNSCR 2498 (2019)
- UNSCR 2551 (2020)
- UNSCR 2713 (2023)
and for the additional statutory purposes set out in the Regulations.
As a whole, this sanctions regime is aimed at promoting the peace, stability and security of Somalia and supporting the Federal Government of Somalia to promote peace, stability, security and the rule of law, including, in particular, supporting its efforts to reconstruct the country, to counter the threats posed by terrorism and from armed groups, and to tackle the flow of illegal arms.
For more details see regulation 4: Purposes.
The legislation.gov.uk webpage tells you if the Regulations are up to date or if there are outstanding amendments. You can also view previous versions using the timeline and a list of the legislation that has affected the regulations which includes:
- the Somalia (Sanctions) (EU Exit) (Amendment) Regulations 2021
- the Somalia (Sanctions) (EU Exit) (Amendment) Regulations 2024
About this guidance
As required by section 43 of the Sanctions and Anti-Money Laundering Act 2018 (‘the Sanctions Act’), the Secretary of State for Foreign, Commonwealth and Development Affairs has provided this guidance to support compliance with the Regulations.
This guidance is designed to give an overview of the prohibitions and requirements, the enforcement of these, and the circumstances in which exceptions and licences may be used. Where appropriate, it directs you to further detailed guidance to read alongside. See all updates to check this guidance is current.
1. Prohibitions and requirements
Sanctions regulations apply to:
- any individual, business or organisation undertaking activities anywhere in the UK (including the territorial sea)
- any business or organisation incorporated or constituted under the law of any part of the UK undertaking activities anywhere in the world
- any UK national, wherever they are in the world
For full details see section 21 of the Sanctions Act.
The maritime enforcement powers contained in Part 9 of the Regulations apply in relation to British ships in international or foreign waters, ships without nationality in international waters and foreign ships in international waters.
It is prohibited to intentionally participate in any activities if you know that the object or effect of them is directly or indirectly to circumvent the prohibitions imposed by the Regulations or to enable or facilitate a breach of those prohibitions.
If you are unclear about any aspects of the Regulations, in particular about whether action you are considering taking could breach the Regulations, you are advised to seek independent legal advice.
1.1 Designation of persons
Designation of persons provisions are contained in Part 2 of the Regulations.
The Regulations provide that the Secretary of State may designate persons for the purposes of financial and/or director disqualification and/or immigration sanctions and/or certain trade sanctions if they are, or have been, involved in a relevant activity (as defined in regulation 6).
The Regulations also provide that each person for the time being named by the United Nations Security Council or Sanctions Committee for the purposes of paragraph 3 of UNSCR 1844 is a designated person for the purposes of the financial sanctions.
Each person for the time being named by the United Nations Security Council or Sanctions Committee for the purposes of paragraph 7 of UNSCR 1844 is a designated person for the purposes of the trade sanctions.
Persons subject to a travel ban under UNSCR 1844 are dealt with under UK immigration regulations. For further information, see Immigration sanctions.
The UK Sanctions List contains the names of all designated persons (DPs) and the sanctions that have been imposed on them. Checking the UK Sanctions List is an essential part of due diligence for many firms and other organisations.
1.2 Financial sanctions
Financial sanctions provisions are contained in Part 3 of the Regulations.
Asset freeze and making available provisions
The Regulations impose financial sanctions through a targeted asset freeze on designated persons and prohibitions on making funds or economic resources available. This involves the freezing of funds and economic resources (non-monetary assets, such as property or vehicles) of designated persons and ensuring that funds and economic resources are not made available to or for the benefit of designated persons, either directly or indirectly.
These prohibitions also apply in relation to entities owned or controlled by a designated person.
If you find out that a person or organisation you are dealing with is subject to the financial sanctions detailed in the Regulations, you must immediately:
- stop dealing with them
- freeze any assets you are holding for them
- inform OFSI as soon as possible
The Office of Financial Sanctions Implementation (OFSI) is the authority responsible for implementing the UK’s financial sanctions on behalf of HM Treasury. OFSI helps to ensure that financial sanctions are properly understood, implemented and enforced in the UK. See more about how OFSI implements financial sanctions.
1.3 Director disqualification sanctions
Director disqualification provisions are contained in Part 3A of the Regulations.
Persons designated under regulation 5 for the purpose of director disqualification sanctions under regulation 17A are disqualified from:
- being a director of a UK company
- directly or indirectly taking part in or being concerned in the promotion, formation or management of a UK company
- being a director of a foreign company that has sufficient connection to the UK, even if it is not registered, for example, if it carries out business or has assets in the UK
under the provisions of:
- section 11A of the Company Directors Disqualification Act 1986 (CDDA)
- Article 15A of the Company Directors Disqualification (Northern Ireland) Order 2002 (CDD(NI)O)
Companies House and the Department for the Economy (Northern Ireland) are responsible for recording information about director disqualification sanctions in their respective Disqualified Director Registers. Companies House is responsible for annotating the Companies Register and preventing registration of a disqualified director’s appointments.
See more information about director disqualification sanctions.
1.4 Trade sanctions
Trade sanctions provisions are contained in Part 5 of the Regulations.
The Regulations impose trade prohibitions relating to:
- military goods and military technology (as specified in Schedule 2 to the Export Control Order 2008);
- improvised explosive devices (IED) components goods and technology (as specified in Part 3 of Schedule 2 of the Regulations, other than anything specified in Schedule 2 to the Export Control Order 2008);
- the provision of technical assistance, armed personnel, financial services or funds or brokering services, where such provision enables or facilitates the conduct of armed hostilities;
- charcoal consigned from and originating from Somalia,
There are circumstances (set out in the relevant lists of controlled items) in which certain items are not controlled, for example when body armour or a helmet is accompanying a person for that person’s own protection. Please check the relevant lists as applicable.
A number of goods subject to prohibitions in the Regulations are identified by reference to commodity codes in the Goods Classification Table[footnote 1]. The UK Tariff sets out a system for the classification of goods to enable importers to ascertain the applicable rate of import duty for their goods. It is this system of classification that is used in the Regulations in order to determine whether goods are within scope of the prohibitions.
This means that where commodity codes are used in the Regulations, the relevant goods are those which would be classified under the relevant commodity code (applying the rules in the UK Tariff) if the goods were being imported to the UK.
Some of the listings of commodity codes in the Regulations have an ‘ex’ before the code. Where this ‘ex’ appears before a commodity code this means that the prohibitions in the Regulations do not apply to all of the items under that commodity code. The prohibitions will only apply to those items that (1) would be classified under the commodity code and (2) that match the description given next to the relevant ‘ex’ code entry in the Regulations.
Further detail on these trade prohibitions, including key terminology used, is explained below. The Regulations contain full definitions of all terms.
Export of certain goods
The concept of ‘export’ is set out in customs legislation, but is further detailed in Paragraph 32 of Schedule 1 to the Sanctions Act, which clarifies that ‘export’ means export from the UK, but does not capture where goods are removed to the Isle of Man from the UK.
The export prohibitions in the Regulations cover:
- certain exports to Somalia as well as certain exports that are for use in Somalia. This means that, even if the immediate destination is not Somalia, the prohibition may still apply;
- certain exports to a designated person (this applies to military goods only). This means that, even if the immediate consignee is not a designated person, the prohibition may still apply.
Exporters should check the ultimate end use of goods and may apply for a licence or contact the Export Control Joint Unit (ECJU) if they think the items may be exported to or for use in Somalia, or if they know or think the items may be exported to a designated person.
Supply and delivery of certain goods
Supply and delivery prohibitions in the Regulations prohibit a person from directly or indirectly supplying or delivering:
- certain goods from a third country to a place in Somalia. Regulation 22 specifies that a third country is a country that is not the UK, Isle of Man or Somalia
- certain goods from a third country to a designated person (this applies to military goods only). Regulation 29 specifies that a third country is a country that is not the UK or the Isle of Man
Entry into Somali ports for temporary visits of vessels carrying military goods and military technology for defensive purposes does not amount to a ‘delivery’ of such items so is not prohibited, provided that such items remain at all times aboard such vessels.
Making certain goods and technology available
Prohibitions in the Regulations on making certain goods or technology available (e.g. through a sale) include directly or indirectly making them available:
- for use in Somalia or to a person ‘connected with’ Somalia. Regulation 20(4) sets out when a person is to be regarded as ‘connected with’ Somalia (and this applies where the term is used in other trade prohibitions in this Part of the Regulations)
- to a designated person (this applies to military goods and military technology only)
Transfer of certain technology
Prohibitions in the Regulations on the transfer of certain technology include:
- transfer to a place in Somalia or a person ‘connected with’ Somalia
- transfer to a designated person (this applies to military technology only)
The term ‘transfer’ is defined in Paragraph 37 of Schedule 1 to the Sanctions Act, which states that it ‘means a transfer by any means (or combination of means), including oral communication and that transfer of goods on which the technology is recorded or from which it can be derived, other than the export of such goods.’
Where military or IED component technology is contained within a good, it would be classified as a military or IED component good under the accompanying goods-related provisions. This includes information contained on USB memory devices, laptops, tablets and the like.
Technical assistance
The term ‘technical assistance’ in relation to certain goods or technology is defined in regulation 20, which states that (except in regulations 35 and 36) it means:
- technical support relating to the repair, development, production, assembly, testing, use or maintenance of the goods or technology, or
- any other technical service relating to the goods or technology
The Regulations prohibit the direct or indirect provision of technical assistance relating to certain military goods or military technology:
- to persons connected with Somalia
- to a designated person
- where the goods are for use in Somalia. This means that, even if the person to whom you are providing the relevant technical assistance is not in or ‘connected with Somalia’, the prohibition may still apply if the goods or technology to which the technical assistance relates are for use in Somalia
Therefore, if you are providing technical assistance, you should check whether the goods or technology may be used in Somalia or may be used by a designated person and apply for a licence or contact ECJU if so.
Financial services and funds related to goods and technology
‘Financial services’ refers to any services of a financial nature in many different forms including insurance and banking. Financial services include payment and money transmission services. The full definition of ‘financial services’ can be found in Section 61 of the Sanctions Act.
‘Funds’ means financial assets and benefits of every kind, including cash, securities and interest. The full definition of ‘funds’ can be found in Section 60 of the Sanctions Act.
Trade sanctions prohibitions on the provision of financial services and funds apply where they relate to certain specified goods or technology.
The prohibitions in the Regulations apply to the direct or indirect provision of financial services, and the direct or indirect making available of funds relating to military goods or military technology, to
- persons connected with Somalia or
- a designated person
in pursuance of or in connection with an arrangement set out in the Regulations, as set out in:
- regulation 26(1)
- regulation 33(1)
This captures arrangements related to the military goods or military technology controlled by the Regulations, for example an arrangement for the export of military goods, or the direct or indirect supply or delivery of military goods.
These prohibitions also prohibit the direct or indirect provision of financial services and funds to anyone, where this is in pursuance of or in connection with specific arrangements, as set out in:
- regulation 26(3)
- regulation 33(3)
This captures arrangements the object or effect of which falls into one of the prohibitions, for example an arrangement for the export of goods to or for the benefit of a designated person.
Brokering services
The definition of ‘brokering services’ is set out in regulation 20, which states that it means any service to secure, or otherwise in relation to, an arrangement, including (but not limited to):
- the selection or introduction of persons as parties or potential parties to the arrangement
- the negotiation of the arrangement
- the facilitation of anything that enables the arrangement to be entered into, and the provision of any assistance that in any way promotes or facilitates the arrangement
The Regulations prohibit the direct or indirect provision of brokering services where they relate to specific arrangements concerning military goods or military technology. Those arrangements are set out in:
- regulation 27
- regulation 34
Other service provisions
Certain services are prohibited in the Regulations. These include the provision of services where such provision enables or facilitates the conduct of armed hostilities in Somalia.
As set out in regulations 35 and 36, the direct or indirect provision of the following services to a designated person, or to a person other than a designated person is prohibited where such provision enables or facilities the conduct of armed hostilities in Somalia:
a) the provision of technical assistance
b) the provision of armed personnel
c) the provision of financial services or funds, or
d) the provision of brokering services in relation to an arrangement whose object or effect is to provide, in a non-UK country any of the services mentioned in paragraphs (a) to (c)
Import of charcoal
The concept of ‘import’ is set out in customs legislation, but is further detailed in Paragraph 33 of Schedule 1 to the Sanctions Act. This clarifies in particular that goods removed to the UK from the Isle of Man are not to be regarded as imported. Paragraph 34 details limited exceptions to this.
The import prohibition in the Regulations covers the import of charcoal consigned from Somalia and originating from Somalia. This means that even if the immediate place the goods were shipped from was not Somalia, the prohibition may still apply. Therefore, importers should check the original place goods were consigned from or contact the DBT Import Controls team if they think the items may have originally been consigned from Somalia.
There are no exceptions or licensing grounds for prohibitions in relation to import of charcoal.
Purchase etc. of charcoal
The Regulations prohibit a person from directly or indirectly acquiring charcoal which originates in Somalia and directly or indirectly acquiring charcoal which is located in Somalia.
Transport of charcoal
The Regulations prohibit a person from directly or indirectly supplying or delivering charcoal from a place in Somalia to a third country, where the charcoal originates in Somalia or is consigned from Somalia. Regulation 39 specifies that a third country is a country that is not the UK, Isle of Man or Somalia.
The Regulations also prohibit a person from directly or indirectly supplying or delivering charcoal from a place in a non-UK country to a place in a different non-UK country, where the charcoal originates in Somalia.
Financial services and funds in relation to charcoal
These prohibitions also prohibit the direct or indirect provision of financial services and funds in pursuance of or in connection with specific arrangements in relation to charcoal, as set out in regulation 40.
Trade sanctions enquiries
The Department for Business and Trade (DBT) leads on trade sanctions. For help with export controls or trade sanctions, contact the Export Control Joint Unit, part of DBT, on: exportcontrol.help@businessandtrade.gov.uk or tradesanctions@businessandtrade.gov.uk
Helpline: +44 (0)20 7215 4594
For further information on import controls, contact DBT’s Import Controls and Sanctions team on: importsanctions@businessandtrade.gov.uk
1.5 Immigration sanctions
Immigration sanctions provisions are contained in Part 4 of the Regulations.
The effect of the Regulations is to impose a travel ban on persons who are designated by the Secretary of State for the purposes of being made subject to immigration sanctions under the Sanctions Act. Such persons are excluded persons for the purposes of section 8B of the Immigration Act 1971.
Persons who are subject to existing designations by the UN Security Council or its Sanctions Committee under UNSCR 1844 for travel ban purposes are not additionally designated under the Regulations as they are already excluded persons for the purposes of section 8B of the Immigration Act 1971.
Individuals designated under either the Regulations or UNSCR 1844 will be refused leave to enter or remain in the UK. Any applications they make for a visa to travel to the UK, including for transit purposes, will be refused. Any foreign national who is subject to a travel ban under the Regulations or UNSCR 1844, and who is currently in the UK, will have their permission to stay in the UK cancelled and steps will be taken to remove them from the UK.
If you are the subject of an immigration sanction and try to travel to the UK, carriers are required to deny you boarding.
See more information on how the Home Office deals with those who are subject to a travel ban.
1.6 Information and record-keeping
Information and record-keeping provisions, including financial sanctions reporting obligations, are contained in Part 7 of the Regulations.
Financial sanctions reporting obligations and information requests
For the purpose of the financial sanctions, the Regulations place obligations on relevant firms to report information to HM Treasury (in practice to the Office of Financial Sanctions Implementation (OFSI), part of HM Treasury) about known or suspected designated persons or about persons who may have breached a prohibition or failed to comply with an obligation under specified provisions of the Regulations.
OFSI has powers to request information from, among others, a designated person, including powers to request the production of documents. It is an offence to fail to comply with these requests or provide false information.
If you are unclear about your obligations or responsibilities, you are advised to seek independent legal advice.
See more guidance about OFSI’s reporting obligations.
Trade sanctions reporting obligations and information requests
The Trade, Aircraft and Shipping Sanctions (Civil Enforcement) (TASSCER) Regulations (2024) place obligations on relevant persons (providers of financial or legal services, or money service businesses, for example) in relation to suspected breaches of certain trade sanctions.
For details see Trade sanctions: reporting obligations.
The Regulations establish powers to request information in relation to the trade sanctions and record-keeping responsibilities for licences. It is an offence to fail to comply with any of these requirements or intentionally obstruct an official in the exercise of these powers.
See more details about information you must provide in response to a trade sanctions information request.
If you are unclear about your obligations or responsibilities, you are advised to seek independent legal advice.
2. Enforcement
Enforcement provisions are contained in Part 8 of the Regulations.
It is a criminal offence to breach sanctions, or to enable or facilitate a breach of, or to circumvent sanctions. The Regulations set out the mode of trial and penalties that apply to such offences.
In some cases, offences are contained in other legislation, such as the Customs and Excise Management Act 1979 (CEMA), or in the regulations made under the Sanctions Act that apply across regimes, such as the TASSCER regulations.
2.1 Financial sanctions enforcement
A breach of the main financial prohibitions or licensing provisions in the Regulations is an offence that is triable either way and carries a maximum sentence on conviction on indictment of 7 years’ imprisonment or a fine, or both.
Offences under the reporting obligations are summary offences and carry a maximum sentence of 6 months’ imprisonment or a fine, or both.
The Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, is responsible for monitoring compliance with financial sanctions and for assessing suspected breaches. It also has the power to impose civil monetary penalties and refer cases to law enforcement agencies for criminal investigation and potential prosecution.
OFSI’s approach to compliance and enforcement is outlined in section 7 of OFSI’s general guidance.
For more information about how OFSI assesses suspected breaches and the possible enforcement outcomes, see OFSI’s enforcement guidance.
2.2 Director disqualification sanctions enforcement
A breach of the main prohibitions or licensing provisions is an offence that is triable either way and carries a maximum sentence on conviction on indictment of 2 years’ imprisonment or a fine, or both.
It is also an offence to provide misleading information to obtain a licence, act outside of permissions given or ignore conditions contained within a licence. A licensing offence carries a maximum sentence on conviction on indictment of 2 years’ imprisonment, or a fine, or both.
The Insolvency Service is responsible for investigating suspected breaches and licensing offences. It has the power to bring prosecutions for breaches and refer cases to other law enforcement agencies for criminal investigation and potential prosecution.
2.3 Trade sanctions enforcement
A breach of the trade sanctions prohibitions is triable either way and carries a maximum sentence on conviction on indictment of 10 years’ imprisonment or a fine, or both.
A breach of the trade sanctions licensing provisions is also triable either way and carries a maximum sentence on conviction on indictment of 2 years’ imprisonment or a fine, or both.
Offences under the reporting obligations are summary offences and carry a maximum sentence of 6 months’ imprisonment or a fine, or both.
HM Revenue and Customs (HMRC) is responsible for enforcing the licensing restrictions and investigating suspected offences.
If you discover that you have breached any of the trade prohibitions or licensing provisions, you should report the irregularity to HMRC (sometimes known as ‘voluntary disclosure’) as soon as possible. If the irregularity was found on an Export Control Joint Unit compliance audit, the compliance inspector will have informed HMRC and you are strongly advised to do the same. Guidance is available on how to make a voluntary disclosure.
3. Exceptions and licences
Exceptions and licensing provisions are contained in Part 6 of the Regulations.
3.1 Exceptions
An exception gives an automatic exemption to an activity that would otherwise be prohibited under sanctions. It means you can carry out that activity as long as certain defined circumstances, set out in the Regulations, apply to your activity.
An exception applies automatically so you do not require a licence to carry out the proposed activity, but some exceptions have notification obligations.
To check the full legal wording of an exception, go to the regulations listed in Part 6. If you are unsure whether an exception applies in your circumstances, you are advised to seek independent legal advice.
General exceptions
Exception for authorised conduct in a relevant country (regulation 45)
This exception relates to prohibitions in regulations 12 to 16, chapter 2 of Part 5 (Trade) and regulation 36
The exception applies if:
- conduct is authorised by a licence or other authorisation that is issued under the law of the Channel Islands, Isle of Man or any British Overseas Territory for the purpose of disapplying a prohibition in that jurisdiction which corresponds to the relevant prohibition
Exception for acts done for purposes of national security or prevention of serious crime (regulation 46)
This exception can be used in relation to any prohibition or requirement imposed by the Regulations.
The exception applies if:
- a responsible officer has determined the relevant actions to be in the interests of national security, or the prevention or detection of serious crime in the UK or elsewhere
Financial sanctions exceptions
Exceptions for crediting a frozen account (regulation 43)
These exceptions relate to the prohibitions in regulations 12 to 14 about dealing with the funds or economic resources of designated persons and making funds available to them. The exceptions permit, in certain circumstances, frozen accounts to be credited by and transfers made to ’relevant institutions’ – those with permission to carry out regulated activities under the Financial Services and Markets Act 2000 part 4A.
See section 6 of OFSI’s general guidance for details about how to use these exceptions and the related reporting obligations for relevant institutions.
Exception for required payments (regulation 43A)
This exception relates to the prohibitions in regulations 12 and 14 about dealing with the funds or economic resources of designated persons and making funds available for their benefit.
The exception permits certain required payments to be made by, or on behalf of, designated persons to various specified UK public bodies.
See OFSI’s FAQs on required payments for details about how to use these exceptions and the related notification obligations.
United Nations exception for humanitarian assistance (regulation 44)
This exception relates to the prohibitions in regulations 12 to 16 about dealing with the funds or economic resources of designated persons and making funds available to them.
The exception applies if the activity is necessary to:
- ensure the timely delivery of humanitarian assistance, or
- to carry out other activities that support basic human needs
See section 9 of OFSI’s financial sanctions guidance for charities and non-governmental organisations (NGOs) to check the conditions for this exception and how to use it.
3.2 Licensing for financial sanctions
A licence is a written permission from OFSI that allows an act that would otherwise be in breach of the financial sanctions prohibitions set out in the regulations.
OFSI has issued general licences that may be used under this regime. For details see OFSI’s general licence page.
In circumstances where there are no applicable exceptions from the prohibitions or general licences, any person (including a designated person) may apply for a licence from OFSI enabling them to deal with the frozen funds or economic resources of the designated person, or to allow these to be made available to or for the benefit of a designated person.
You should not assume that a licence will be granted or engage in any activities prohibited by financial sanctions until your licence has been granted.
Licensing grounds for financial sanctions
OFSI can only issue individual licences where:
- there is a relevant licensing ground
- the conditions set out in that licensing ground have been met, and
- OFSI considers it appropriate to issue a licence for that purpose
The purposes and activities for which OFSI may grant an individual licence are set out in Schedule 3 to the Regulations. In summary these include:
- basic needs
- reasonable professional fees for or reasonable expenses associated with the provision of legal services
- reasonable fees or service charges arising from the routine holding or maintenance of frozen funds or economic resources
- extraordinary expenses
- judicial decisions etc [footnote 2]
- diplomatic missions etc (non-UN designated persons only)
- prior obligations (non-UN designated persons only)
- extraordinary situations (non-UN designated persons only)
- insolvency (non-UN designated persons only)
In some cases, OFSI may need to notify, or seek approval from the relevant United Nations Sanctions Committee before issuing a licence. These requirements are set out in the relevant UN Security Council Resolutions. These requirements will lengthen the processing time for such licence applications and may in some cases prevent a licence from being issued.
See section 6.6 of OFSI’s general guidance for the approach OFSI takes when deciding whether to grant a licence for each of these licensing grounds.
See OFSI’s licensing page for licence application forms and guidance.
3.3 Licensing for director disqualification sanctions
The designated person, or their authorised representative, can make an application for a licence to the Insolvency Service. See more details about how to apply.
The Insolvency Service will assess and grant or refuse licence applications on behalf of the Secretary of State. Companies House is responsible for updating the Companies Register when a licence is granted.
You should not assume that a licence will be granted or act as the director of a company – or directly or indirectly take part in or be concerned in the promotion, formation or management of a company – until your licence has been granted.
3.4 Licensing for trade sanctions
Licences may also be issued for certain trade activities that would otherwise be prohibited by the Regulations. The Department for Business and Trade has overall responsibility for trade sanctions licensing. The Secretary of State for Business and Trade is ultimately responsible for decisions to grant or refuse a trade sanctions licence in any individual case.
The Export Control Joint Unit (ECJU), part of DBT, is responsible for licensing the export of sanctioned goods, software and technology.
The Export Control Joint Unit (ECJU), part of DBT, is responsible for licensing the export of sanctioned goods, software and technology. See how to apply for an export licence. Information on the activities you wish to carry out and relevant documentation can be provided in a cover letter and attached to the application.
In making decisions on whether to grant a licence to permit something which would otherwise be prohibited under Part 5 of the Regulations, the Secretary of State will consider each application on a case-by-case basis to determine whether granting a licence would be consistent with the stated purposes of the sanctions regime and any UN or other relevant international law obligations.
For some prohibitions there are some specific activities that DBT considers are likely to be consistent with the aims of the sanctions. These are set out in the table below. If you think that your proposed activity falls within one of these specific descriptions you should make this clear and explain why you believe this to be the case in your application for a licence.
Some of the licensing grounds set out below include requirements relating to the UN Security Council Sanctions Committee on Somalia (‘UNSC’):
- where the Secretary of State is required to give the UNSC notice of a licence granted under this sanctions regime, the Secretary of State will first determine whether granting a licence would be consistent with the purposes set out in the Regulations. If the Secretary of State determines that granting a licence would be consistent with those purposes and go on to grant a licence, the UK (via the FCDO) will notify the UNSC
- where approval from the UNSC is required in order to grant a licence, the Secretary of State will first determine whether granting the licence would be consistent with the purposes set out in the Regulations. If the Secretary of State determines that granting a licence would be consistent with those purposes, the UK (via the FCDO) will submit the necessary information to the UNSC to seek the approval of the committee. The Secretary of State will only grant a licence when confirmation of the Committee’s approval has been received
You should not assume that a licence will be granted or engage in any activities prohibited by trade sanctions until your licence has been granted.
Considerations for trade sanctions licences
| Prohibitions | Type of consideration |
|---|---|
| Regulations 21 to 24 | Considerations for the export, making available, transfer, supply or delivery of military goods, military technology, IED component goods or IED component technology |
A licence may be granted for the export, making available, transfer, supply or delivery of military goods or military technology if the goods or technology are intended solely for the support of or use by:
- Government of the Federal Republic of Somalia
- Somali National Army
- Somalia’s National Intelligence and Security Agency
- the Somali National Police Force and the Somali Custodial Corps
- United Nations personnel, including the United Nations Assistance Mission in Somalia (UNSOM) and the United Nations Support Office in Somalia (UNSOS)
- the African Union Transition Mission in Somalia (ATMIS) and its Troop- and Police-Contributing Countries, as well as its strategic partners who are operating solely under the latest African Union Strategic Concept of Operations and in cooperation and coordination with The African Union Transition Mission in Somalia (ATMIS)
- European Union training and support activities, Türkiye, the United Kingdom of Great Britain and Northern Ireland and the United States of America, as well as any other Member State forces, with a status of forces agreement or a memorandum of understanding with the Federal Government of Somalia, provided that they inform the Committee, for information purposes only, about the existence of such agreements.
A licence may be granted for the export, making available, transfer, supply or delivery of the items specified in Annex A of UNSCR 2713 (2023) as amended from time to time, to Federal Member States and regional governments, or to licensed private security companies operating in Somalia to provide security for international and commercial premises and personnel in Somalia subject to the absence of a negative decision by the United Nations Sanctions Committee (UNSC) within 5 working days of receiving a notification from the Government of the Federal Republic of Somalia.
A licence may be granted for the export, making available, transfer, supply or delivery of the items specified in Annex B to UNSCR 2713 (2023) as amended from time to time, to Federal Member States and regional governments, or to licensed private security companies operating in Somalia to provide security for international and commercial premises and personnel in Somalia subject to notification to the United Nations Sanctions Committee, at least 5 working days in advance by the Government of the Federal Republic of Somalia.
A licence may be granted for the export, making available, transfer, supply or delivery of the improvised explosive device components listed in Part 3 of Schedule 2 of the Regulations, unless there is sufficient evidence to demonstrate that the items will be used, or a significant risk they may be used, in the manufacture in Somalia of improvised explosive devices.
This is subject to UNSC notification within 15 working days after the activity takes place.
A licence may be granted for the technical assistance, brokering services, financial services and funds relating to non-lethal military goods or military technology if the goods and technology are intended solely for humanitarian or protective use.
| Prohibitions | Type of consideration |
|---|---|
| Regulations 25 to 27 | Considerations for the provision of technical assistance, financial services, funds, and brokering services relating to military goods or military technology |
A licence may be granted for the provision of technical assistance, brokering services, financial services and funds relating to military goods or military technology if the technical assistance, brokering services, financial services or funds are intended solely for the support of or use by:
- Government of the Federal Republic of Somalia
- Somali National Army
- Somalia’s National Intelligence and Security Agency
- the Somali National Police Force and the Somali Custodial Corps
- United Nations personnel, including the United Nations Assistance Mission in Somalia (UNSOM) and the United Nations Support Office in Somalia (UNSOS)
- the African Union Transition Mission in Somalia (ATMIS) and its Troop- and Police-Contributing Countries, as well as its strategic partners who are operating solely under the latest African Union Strategic Concept of Operations and in cooperation and coordination with The African Union Transition Mission in Somalia (ATMIS)
- European Union training and support activities, Türkiye, the United Kingdom of Great Britain and Northern Ireland and the United States of America, as well as any other Member State forces, with a status of forces agreement or a memorandum of understanding with the Federal Government of Somalia, provided that they inform the Committee, for information purposes only, about the existence of such agreements
A licence may be granted for the export, making available, transfer, supply or delivery of the items specified in Annex B to UNSCR 2713 (2023) as amended from time to time, to Federal Member States and regional governments, or to licensed private security companies operating in Somalia to provide security for international and commercial premises and personnel in Somalia subject to notification to the United Nations Sanctions Committee, at least 5 working days in advance by the Government of the Federal Republic of Somalia.
A licence may be granted for the export, making available, transfer, supply or delivery of the items specified in Annex B to UNSCR 2713 (2023) as amended from time to time, to Federal Member States and regional governments, or to licensed private security companies operating in Somalia to provide security for international and commercial premises and personnel in Somalia subject to notification to the United Nations Sanctions Committee, at least 5 working days in advance by the Government of the Federal Republic of Somalia.
A licence may be granted for the technical assistance, brokering services, financial services and funds relating to non-lethal military goods or military technology if the goods and technology are intended solely for humanitarian or protective use.
There are no exceptions or licensing grounds for prohibitions involving designated persons.
The UN Security Council has set out in paragraphs 4, 33, 34 and 35 of UNSCR 2713 a number of derogations, some of which may be relevant to the prohibitions on enabling or facilitating the conduct of armed hostilities (regulation 36). If you think that your proposed activity would otherwise be prohibited by the prohibitions set out in regulation 36 of the Regulations, but meets the criteria set out in paragraphs 4 ,33, 34, or 35 of UNSCR 2713 and is consistent with the aims of the sanctions, then you should make this clear, and explain why you believe this to be the case, in your application for a licence. Where relevant, the Secretary of State may notify or seek the approval of the UNSC, when considering your application for a licence.
When you export or import goods, you may need to submit a declaration: guidance is available on:
Overlap with strategic export licensing
Military goods and military technology
Please note that the export of and trade in military goods and military technology are also controlled under the Export Control Order 2008 and so you may also need a licence which is valid under that legislation. This means that all licence applications relating to military goods and military technology will also need to be considered against the Strategic Export Licensing Criteria. A licence under the Regulations is unlikely to be granted if a licence is refused for the same activity under the Export Control Order 2008.
The way this will work in practice is that we will consider an application for a licence which relates to activities that are licensable under both the Regulations and the Export Control Order 2008 as an application for a licence under both pieces of legislation. This means that only a single licence application is required.
The application will be considered against the relevant licensing criteria. If a licence is granted it will be valid under both the Export Control Order 2008 and the Regulations.
Overlap between trade sanctions and financial sanctions
If you import or export goods, you need to consider if financial sanctions apply to you. You may need a licence from OFSI as well as from ECJU, OTSI or the Import Controls Team. See the guidance on licensing for more details.
Transit control
Certain goods transiting the UK are still regarded as being exported when they leave the country and are therefore subject to control. Article 17 of the Export Control Order 2008 includes a transit and transhipment exception meaning that in many situations a licence is not required. This exception does not apply to goods destined for Somalia, meaning that a licence is required to transit goods through the UK or to tranship them in the UK with a view to re-exportation to Somalia.
3.5 Directions in respect of immigration sanctions
If you are subject to immigration sanctions the Home Office may direct, on a case by case basis, that the sanction does not apply in particular circumstances, such as for travel to, or through, the UK for a UN sponsored meeting. You can check how to apply for a UK visa, and find further information about travelling to the UK on GOV.UK.
4. Further information
The UK sanctions hub page is a central point for all sanctions content, including links to introductory guidance, sector-specific guidance, reporting obligations, blogs, and email alert services.
You can report a suspected breach of sanctions if you think you, or someone else, may have breached sanctions, or be attempting to circumvent sanctions.
For specific queries about this sanctions regime, email: fcdo.correspondence@fcdo.gov.uk
For other contact details, see Government departments and agencies responsible for sanctions.