Statutory guidance

Syria cultural property sanctions: statutory guidance

Updated 25 March 2026

Introduction

This guidance is about the trade sanctions imposed by The Syria (United Nations Sanctions) (Cultural Property) (EU Exit) Regulations 2020 (‘the Regulations’).

About the Regulations

The Regulations impose sanctions for the purpose of giving effect to the United Kingdom’s obligations under United Nations Security Council Resolution:

• UNSCR 2199 (2015)

UNSCR 2199 includes an obligation to take steps to prevent the trade in Syrian cultural property and other items of archaeological, historical, cultural, rare scientific and religious importance illegally removed from Syria since 15 March 2011, thereby allowing for their eventual safe return to the Syrian people.

For more details see regulation 4: Purpose.

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.

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 6 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 Trade sanctions

Trade sanctions provisions are contained in Part 2 of the Regulations.

The Regulations impose trade prohibitions relating to illegally removed Syrian cultural property. Further detail on these trade prohibitions, including key terminology used, is explained below. The Regulations contain full definitions of all terms.

Regulation 5 defines ‘illegally removed Syrian cultural property’ as Syrian cultural property or any other item of archaeological, historical, cultural, rare scientific or religious importance illegally removed from any location in Syria on or after 15 March 2011.

Regulations 7 to 12 prohibit the export and import and the direct or indirect supply, delivery, making available and acquisition of illegally removed Syrian cultural property. They also prohibit the direct or indirect provision of financial services, funds or brokering services in connection with an arrangement whose object or effect is one of these prohibited acts. A person who holds or controls illegally removed Syrian cultural property must secure its transfer to a constable.

Export of illegally removed Syrian cultural property

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 of illegally removed Syrian cultural property is prohibited under the Regulations.

A sanctions licence is not required for exports of non-military goods covered by the Regulations from Northern Ireland to an EU Member State where the final destination is Syria. You will however have to comply with any licensing requirements that apply in the relevant EU Member State for the onward export to Syria. You will also have to comply with any other licensing requirements under UK export control legislation as applicable.

Import of illegally removed Syrian cultural property

The import of illegally removed Syrian cultural property is prohibited under the Regulations. 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 Isle of Man are not to be regarded as imported. Paragraph 34 details limited exceptions to this.

Supply and delivery of illegally removed Syrian cultural property

Supply and delivery prohibitions in the Regulations prohibit a person from directly or indirectly supplying or delivering illegally removed Syrian cultural property from a third country to any other third country. Regulation 8 specifies that a third country is a country that is not the UK or the Isle of Man.

Making available or acquisition of illegally removed Syrian cultural property

These prohibitions prohibit a person from directly or indirectly:

1. making available (e.g. through a sale) illegally removed Syrian cultural property to another person
2. acquiring illegally removed Syrian cultural property from another person

Financial services and funds relating to illegally removed Syrian cultural property

‘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 to another person of financial services or funds in pursuance of or in connection with an arrangement relating to illegally removed Syrian cultural property, as set out in the Regulations. This captures arrangements the object or effect of which falls into one of the prohibitions concerning illegally removed Syrian cultural property, for example the export or import of illegally removed Syrian cultural property.

Brokering services

The definition of ‘brokering services’ is set out in regulation 6, 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 involving illegally removed Syrian cultural property. Those arrangements are set out in regulation 11(1).

Trade sanctions enquiries

The Department for Digital, Culture, Media and Sport (DCMS) has overall responsibility for cultural property policy. For general enquiries on cultural property issues, contact the DCMS Cultural Property Unit on: culturalpropertymailbox@dcms.gov.uk

It is not possible to get a trade sanctions licence for cultural property. For enquiries and guidance on export licences for cultural property, contact the Export Licensing Unit at Arts Council England on: elu@artscouncil.org.uk

1.2 Information and record-keeping

Information and record-keeping provisions, including financial sanctions reporting obligations, are contained in Part 4 of the Regulations.

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 those 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 5 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 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 licensing

Exceptions and licensing provisions are contained in Part 3 of the Regulations.

3.1 Exceptions

The Regulations set out exceptions to some of the sanctions prohibitions which apply within certain defined circumstances. An exception applies automatically, and does not require you to obtain a licence issued in accordance with the Regulations. However, other types of licence, such as an export licence, might still be required.

Exception for the safe return of cultural property (regulation 15)

This exception relates to the prohibitions in chapter 2 of part 2 about illegally removed Syrian cultural property.

The exception applies if anything is done:

• to facilitate the safe return of items to their legitimate owners in Syria in accordance with the objectives of paragraph 17 of resolution 2199

Exception for acts done for purposes of national security or prevention of serious crime (regulation 16)

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 If you are unsure whether an exception applies in your circumstances, you are advised to seek independent legal advice.

3.2 Licensing for trade sanctions

The Regulations do not contain a power to issue licences in respect of trade sanctions.

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.