Statutory guidance

Syria sanctions: guidance

Updated 25 April 2025

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 assist in the implementation of, and compliance with, the Syria (Sanctions) (EU Exit) Regulations 2019 (the ‘Regulations’), as amended from time to time.

The legislation’s 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.

Instruments that have made amendments

• the Sanctions (EU Exit) (Miscellaneous Amendments) (No.2) Regulations 2020
• the Sanctions (EU Exit) (Miscellaneous Amendments) (No.4) Regulations 2020
• the Syria (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2024
• the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2025
• the Syria (Sanctions) (EU Exit) (Amendment) Regulations 2025

This document contains guidance on the prohibitions and requirements imposed by the Regulations. It additionally provides guidance on best practice for complying with the prohibitions and requirements, the enforcement of them, and circumstances where they do not apply.

The guidance is designed to give an overview of the prohibitions and requirements in the Regulations and, where appropriate, direct you to further detailed guidance to read alongside it. This document is current on the date of publication.

1. Prohibitions and requirements

The Regulations impose financial, director disqualification, trade, and immigration sanctions for the purposes of  promoting the peace, stability and security of Syria, promoting respect for democracy, the rule of law and good governance in Syria, including in particular promoting the successful completion of Syria’s transition to a democratic country, to discourage actions, policies or activities which repress the civilian population in Syria, promoting compliance with international human rights law and respect for human rights in Syria, and providing accountability for gross violations of human rights carried out by or on behalf of the Assad regime.

The prohibitions and requirements imposed by the Regulations apply within the territory of the United Kingdom (UK) (including Northern Ireland) and in relation to the conduct of all UK persons wherever they are in the world. UK persons include British nationals, as well as all bodies incorporated or constituted under the law of any part of the UK. Accordingly, the prohibitions and requirements imposed by the Regulations apply to all companies established in any part of the UK, and they also apply to branches of UK companies operating overseas.

The maritime enforcement powers contained in Part 10 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 the contravention of those prohibitions.

If you are unclear about any aspect of the Regulations, in particular about whether action you are considering taking could contravene the Regulations, you are advised to seek independent legal advice.

Prohibitions and requirements for the financial, director disqualification, trade, and immigration sanctions contained in the Regulations are set out below.

1.1 Designation of persons

The Regulations provide that the Secretary of State may designate persons for the purposes of financial and/or director disqualification and/or immigration sanctions if they are, or have been, involved in a relevant activity (as defined in regulation 6).

The UK Sanctions List lists the people designated under the Regulations, and details of the sanctions in respect of which they have been designated.

1.2 Financial sanctions

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.

Based on the designation criteria contained in the Regulations, this means that asset freezes are imposed on those persons who are designated as a result of carrying on prohibited activities in Syria related to chemical weapons, including developing, producing, acquiring, stockpiling or retaining chemical weapons, transferring chemical weapons to any person, using chemical weapons, engaging in any military preparations to use chemical weapons, and providing assistance to or encouraging or inducing any person to engage in any of the above activity.

Asset freezes are also imposed on those persons who are designated for providing financial services or making funds or economic resources available to those that are or have been involved in repressing the civilian population in Syria (including those who were involved in repressing the civilian population under the Assad regime or supporting or benefitting from the Assad regime).

Asset freezes are also imposed on those persons who are designated because of their involvement in the supply to Syria of restricted goods or restricted technology or of material related to such goods or providing financial services related to such supply.  Asset freezes are also impose on those who are designated for their involvement in supplying goods or technology to Syria, or providing financial services relating to such a supply, which could contribute to repressing the civilian population  (including those who were involved in repressing the civilian population under the Assad regime or supporting or benefitting from the Assad regime.  Finally, asset freezes are also imposed on those persons who are designated for, amongst other things, their involvement in repressing the civilian population in Syria or undermining democracy, the rule of law or good governance in Syria.

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 United Kingdom. See more information about how OFSI implements financial sanctions.

Assad regime bonds

Any sale or purchase of public bonds or public-guaranteed bonds issued by the Assad regime between 19 January 2012 and 8 December 2024 must not be made to or from any Syrian credit or financial institution, to or from any person acting on behalf of those mentioned above or at their direction, or to or from an entity owned or controlled by them. Nor must any person provide brokering, advertising or other services which assist with the sale or purchase of public or public-guaranteed bonds that were issued during the Assad regime.

1.3 Director disqualification sanctions 

Where a person is designated under regulation 5 for the purpose of director disqualification sanctions under regulation 23A, this means that they are subject to the provisions of section 11A of the Company Directors Disqualification Act 1986 (CDDA) and Article 15A of the Company Directors Disqualification (Northern Ireland) Order 2002 (CDD(NI)O).    

The effect of the provision is to disqualify persons designated for this purpose under regulation 5 from being a director of a UK company or directly or indirectly taking part in or being concerned in the promotion, formation or management of a company. 

Under section 11A of CDDA (and, in Northern Ireland, under the equivalent Article 15A of CDD(NI)O), it will be an offence for a person subject to ‘director disqualification sanctions’ as set out in section 3A of the Sanctions and Anti-Money Laundering Act 2018 (SAMLA) to act as a director of a company or directly or indirectly to take part in or be concerned in the promotion, formation or management of a company, unless a licence has been issued by virtue of the powers granted in section 15(4A) of SAMLA and set out in regulation 61A. 

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. The Insolvency Service will assess and grant or refuse licence applications on behalf of the Secretary of State. The Insolvency Service also has the power to bring prosecutions for breaches of the legislation, and, where appropriate, to refer cases to other law enforcement agencies for potential prosecution.

1.4 Trade sanctions

The Regulations impose trade prohibitions relating to:

• military goods and military technology (as specified in Schedule 2 to the Export Control Order 2008)
• any thing which falls within Chapter 93 of the Goods Classification Table[footnote 1], other than military goods
• goods and technology relating to chemical and biological weapons (as specified in Schedule 3 to the Regulations[footnote 2])
• interception and monitoring goods and technology (as specified in Schedule 4 to the Regulations)
• interception and monitoring services (Technical guidance on interception and monitoring is available)
• internal repression goods and technology (as specified in Schedule 5 to the Regulations)
• gold, precious metals or diamonds (as specified in Part 2 (6) of Schedule 2 to the Regulations)
• luxury goods (as specified in Part 2 (7) of Schedule 2 to the Regulations)

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. 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. Please have regard to the relevant legislation which contains full definitions of terms used herein.

The term “regulation 28 goods” and “regulation 28 technology” is used below to refer to the following items, which the trade restrictions at Chapter 2 relate to:

• goods and technology relating to chemical and biological weapons
• interception and monitoring goods and technology
• internal repression goods and technology; and

Export of 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 regulation 29 (regulation 28 goods)  covers exports to Syria as well as exports that are for use in Syria.

The export prohibition in regulation 42 (gold, precious metals or diamonds) covers exports to the “Governing Authority of Syria”  as defined in regulation 27(6). The export prohibition in regulation 46 (luxury goods) covers exports to Syria.

This means that, even if the immediate destination is not Syria, the prohibition may still apply. Exporters should check the ultimate end use of goods and may apply for a licence. If you know or think the items may be used in a way that would breach a prohibition, you should report the irregularity to the appropriate authority as soon as possible. For more information, please refer to 2.3 Trade Enforcement section. 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 goods

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 regulation 36 (arms and related materiel) covers imports that are consigned from Syria and goods that originated in Syria. The import prohibition in regulation 42 (gold, precious metals or diamonds) covers imports consigned from the “Governing Authority of Syria” as defined in regulation 27(6). This means that even if the immediate place the goods were shipped from was not Syria, the prohibition may still apply. Therefore, importers should check the original place goods were consigned from and apply for a licence or contact DBT’s Import Licensing Branch if they think the items may have originated in Syria or been consigned from Syria or from the “Governing Authority of Syria”.

A sanctions licence is not required for imports of non-military goods covered by the Regulations from an EU Member State into Northern Ireland which originate in or are consigned from Syria. You will however have to comply with any licensing requirements that apply in the relevant EU Member State for the original import into the customs territory of the EU. You will also have to comply with any other licensing requirements under UK import control legislation as applicable.

Supply and delivery of goods

Supply and delivery prohibitions in regulations 30 (regulation 28 goods) and 46 (luxury goods) prohibit a person from directly or indirectly supplying or delivering certain goods from a third country to a place in Syria.

Regulation 38 (military goods) prohibits a person from directly or indirectly supplying or delivering certain goods originating in or consigned from Syria from a place in Syria to a ‘third country’.

Regulation 42 (gold, precious metals or diamonds) prohibits a person from directly or indirectly supplying or delivering certain goods from a third country to the “Governing Authority of Syria” as defined in regulation 27(6). It also covers the movement of those goods from the “Governing Authority of Syria” to a place in a ‘non-UK country’.

‘Third country’ and ‘non-UK country’ are defined in each regulation.

Making goods and technology available

The prohibition in regulation 31 (regulation 28 goods and technology) on making goods or technology available (e.g. through a sale) covers directly or indirectly making them available for use in Syria or to a “person connected with Syria”.

Regulation 42 (gold, precious metals or diamonds) prohibits directly or indirectly making certain goods available to the “Governing Authority of Syria”  as defined in regulation 27(6). Regulation 46 (luxury goods) covers making certain goods available to a person connected with Syria.

Regulation 27(5) sets out when a person is to be regarded as “connected with” Syria (and this applies where the term is used in other trade prohibitions in Chapter 2 and 4 of the Regulations).

Acquisition of goods and technology

The prohibition in regulation 37 (military goods and technology) on the acquisition of certain goods and technology includes directly or indirectly acquiring certain goods or technology originating in Syria, which are located in Syria, or from a person connected with Syria.

Regulation 42 (gold, precious metals or diamonds) covers the acquisition of goods from “Governing Authority of Syria” as defined in regulation 27(6).

Transfer of technology

The prohibition in regulation 32 (regulation 28 technology) on the transfer of technology includes transfer to a place in Syria or a person connected with Syria. Regulation 39 (military technology) covers the transfer of military technology to persons or places outside the UK where the transfer is from a place in Syria.

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 technology relating to chemical and biological weapons, interception and monitoring technology, internal repression technology or military technology is contained within a good, that good would be classified as falling under the respective category of controlled 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 goods and technology is defined in regulation 27, which states that 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

Prohibitions apply where the technical assistance relates to certain specified goods or technology.

The prohibition in regulation 33 (regulation 28 goods and technology) applies to the direct or indirect provision of such technical assistance (1) to persons “connected with Syria” or (2) for use in Syria.

This means that, even if the person to whom you are providing technical assistance is not in or “connected with Syria”, the prohibition may still apply if the goods or technology to which the technical assistance relates are for use in Syria. Therefore, if you are providing technical assistance you should check whether the goods or technology may be used in Syria and apply for a licence or contact ECJU.

Regulation 43 (gold, precious metals or diamonds) prohibits the direct or indirect provision of technical assistance to the “Governing Authority of Syria” as defined in regulation 27(6).

Financial services and funds related to goods and technology

‘Financial services’ refer 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 to persons connected with Syria in pursuance of or in connection with an arrangement set out in the Regulations at regulation 34(1). This captures arrangements where the object or effect falls into one of the prohibitions, for example the export of certain goods or direct or indirect supply or delivery of certain goods (regulation 28 goods and technology).

These prohibitions also prohibit the direct or indirect provision of financial services or funds in pursuance of or in connection with specific arrangements as set out at regulation 34(3).

Prohibitions in regulation 40 prohibit the direct or indirect provision of financial services or funds in pursuance of or in connection with an arrangement set out at regulation 40(1), which includes arrangements relating to military goods and technology.

Prohibitions in regulation 44 (gold, precious metals or diamonds) prohibit the direct or indirect provision of financial services and the direct or indirect making available of funds to the “Governing Authority of Syria” (as defined in regulation 27(6)) in pursuance of or in connection with arrangements set out at regulation 44(1). These prohibitions also prohibit the direct or indirect provision of financial services or funds in connection with specific arrangements set out at regulation 44(3).

Brokering services

The definition of ‘brokering services’ is set out in regulation 2, 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

Regulation 35 prohibits the direct or indirect provision of brokering services where they relate to specific arrangements (concerning regulation 28 goods and technology).

Regulation 45 (gold, precious metals or diamonds) prohibits the direct or indirect provision of brokering services to the “Governing Authority of Syria” in relation to an arrangement set out at regulation 45(1), and the direct or indirect provision of such services in relation to an arrangement at regulation 45(2).

Other service provisions

Certain other services are prohibited in these regulations. This includes the provision of interception and monitoring services to or for the benefit of the “Governing Authority of Syria”[footnote 4] (regulation 48). The definition of ‘interception and monitoring services’ is set out in regulation 20.

DBT contact details

DBT has 3 licensing bodies responsible for administering licences on behalf of the Secretary of State. Which body you need to apply through is dependent on the activity you want to carry out. If you want to carry out activity which falls under the remit of more than one licensing body, you will need to submit separate licence applications to each one.

For further information on licensing, compliance and enforcement for trade sanctions relating to standalone services, contact the Office of Trade Sanctions Implementation (OTSI).

For further information on export controls and trade sanctions relating to the export of goods and provision of ancillary services, contact ECJU.

For further information on import controls, contact DBT’s Import Licensing Branch at importcontrols@businessandtrade.gov.uk

1.5 Immigration sanctions

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.

Designated individuals 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, and 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.

1.7 Information and record keeping

For the purpose of the financial sanctions contained in the Regulations, Part 8 of the Regulations places obligations on relevant firms (the definition of which is set out in the Regulations) to report information to 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.

It also grants powers to HM Treasury to request information from, amongst others, a designated person, including powers to request the production of documents. It also establishes offences for failing to comply with these requests (including for providing false information).

Part 8 also establishes information powers and record-keeping responsibilities in relation to the trade sanctions contained in the Regulations. It provides for offences for failing to comply with any of those requirements or intentionally obstructing an official in the exercise of those powers.

If you have obligations or responsibilities under Part 8 of the Regulations, it is important that you familiarise yourself with them. If you are unclear of your obligations or responsibilities, you are advised to seek independent legal advice.

See more information about OFSI’s reporting requirements.

2. Enforcement

The Regulations make it a criminal offence to contravene the trade and financial sanctions, as well as to enable or facilitate a contravention of, or to circumvent, any of the prohibitions in the Regulations. They also prescribe the mode of trial and penalties that apply to such offences. In some cases, offences related to contraventions of prohibitions in the Regulations are contained within other legislation, such as the Customs and Excise Management Act 1979 (CEMA).

In addition to the below, further details on offences and penalties are in the corresponding report under section 18 of the Sanctions Act.

2.1 Financial sanctions enforcement

A breach of financial sanctions is a serious criminal offence. Any breach of the main financial prohibitions in the Regulations is an offence that is triable either way and carries a maximum sentence on indictment of 7 years’ imprisonment or a fine (or both).

Offences under regulations 69(6) or 73 (information offences in connection with financial sanctions under the Regulations) are summary offences only and carry a maximum sentence of 6 months’ imprisonment or a fine (which in Scotland or Northern Ireland may not exceed level 5 on the standard scale) or both.

OFSI is responsible for monitoring compliance with financial sanctions and for assessing suspected breaches. It also has the power to impose monetary penalties for breaches of financial sanctions and to refer cases to law enforcement agencies for investigation and potential prosecution.

OFSI works with other parts of government, supervisory bodies and regulators to consider all cases reported to it, sharing relevant information accordingly.

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 by emailing ofsi@hmtreasury.gov.uk or by calling their general enquiries line: +44 (0)20 7270 5454

See more detailed information on OFSI’s approach to compliance and enforcement in section 7 of OFSI’s general guidance.

2.2 Director disqualification sanctions enforcement

A breach of director disqualification sanctions is an offence under CDDA and CDD(NI)O.  

The Insolvency Service is responsible for monitoring compliance with disqualified director sanctions and for assessing suspected breaches of the main prohibitions and the licensing prohibitions. It also has the power to bring prosecutions for breaches under section 11A CDDA and refer cases to other law enforcement agencies for potential prosecution. 

Under section 13 of CDDA (and in Northern Ireland, under Article 18 of CDD(NI)O), a person guilty of acting in contravention of the new section 11A (in Northern Ireland, Article 15A of CDD(NI)O) will be liable (a) on conviction on indictment, to imprisonment for not more than 2 years or a fine, or both; and (b) on summary conviction, to imprisonment for not more than 6 months or a fine not exceeding the statutory maximum, or both.

2.3 Trade sanctions enforcement

Any breach of the trade sanctions prohibitions in the Regulations is triable either way and carries a maximum sentence on indictment of 10 years’ imprisonment or a fine (or both). Any breach of the trade licensing provisions is also triable either way and carries a maximum sentence on indictment of 2 years’ imprisonment or a fine (or both).

The Office of Trade Sanctions Implementation (OTSI) in DBT is responsible for monitoring compliance with trade sanctions and investigating suspected breaches in relation to:  

• providing or procuring sanctioned services
• moving, making available, or acquiring sanctioned goods outside the UK
• transferring, making available or acquiring sanctioned technology outside the UK
• providing ancillary services to the movement, making available or acquisition of sanctioned goods outside the UK
• providing ancillary services to the transfer, making available or acquisition of sanctioned technology outside the UK

OTSI can issue warnings and use their powers to publish information about breaches, impose civil monetary penalties and refer cases to HM Revenue and Customs (HMRC) for criminal investigation. OTSI can also report individuals and businesses to their regulator, if they have one, and share information with organisations such as Companies House or the Insolvency Service.  

Trade sanctions apply to:  

• all individuals or businesses within the territory and territorial sea of the UK
• all UK nationals or UK businesses established under UK law, wherever they are in the world

This means OTSI can investigate suspected breaches committed by:  

• individuals and legal entities who are within, or undertake activities within, the UK’s territory
• UK individuals and legal entities established under UK law, regardless of where in the world the breach takes place

HMRC is responsible for the enforcement of trade sanctions that fall within its remit as the UK’s customs authority and for the enforcement of trade sanctions measures that relate to strategic goods and technology.

HMRC has a range of enforcement options available such as education, warning letters, issuing compound settlements, seizures,  disruptions and in the most serious of cases, referral to the Crown Prosecution Service for consideration for prosecution.

If you discover that there may have been a breach of any of the trade prohibitions or licensing provisions, you should report the irregularity to the appropriate authority as soon as possible.

• report a suspected breach to HMRC using this email: exports.strategic@hmrc.gov.uk
• report a suspected breach to OTSI using the Report a breach tool

If the irregularity was found on an ECJU compliance audit, the compliance inspector will have informed HMRC and you are strongly advised to do the same. See guidance on how to make a voluntary disclosure.

3. Licensing and exceptions

Licensing and exception provisions are contained in Part 7 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.

The Regulations establish exceptions relating to financial sanctions including for the crediting of a frozen account by a relevant institution (any such interest and other earnings will be frozen in accordance with the relevant legislation underpinning the asset freeze). An exception also exists from the prohibition on making funds available to a designated person, when funds are transferred to a frozen account in discharge (or partial discharge) of an obligation which arose before the recipient became a designated person.

The Regulations also provide exceptions to asset freeze prohibitions relating to the use of petroleum products by diplomatic missions where these products are exclusively for the official use of that mission. There is also an equivalent humanitarian assistance exception from the relevant asset freeze prohibitions under the Regulations. This exception applies when a “relevant person” makes available funds or economic resources for the purposes of either:

• acquiring, supplying or delivering petroleum products; or
• providing funds, economic resources or financial services in relation to those activities; and where the petroleum products are acquired, supplied or delivered exclusively for the purposes of providing a humanitarian assistance activity.

The exception to the asset freeze prohibitions also applies to persons providing financial services, funds or economic resources to a “relevant person” in relation to their reliance on the exception. 

A “relevant person” means:

(a) any person that receives funding from any part of the Government of the United Kingdom for the purpose of providing a humanitarian assistance activity in Syria;

(b) the United Nations[footnote 1], including its—

(i) specialised agencies and related organisations; and

(ii) other entities and bodies;

(c) international organisations carrying out humanitarian assistance activities in Syria other than those described in sub-paragraph (b);

(d) humanitarian organisations having observer status with the United Nations General Assembly and members of those humanitarian organisations;

(e) bilaterally or multilaterally funded non-governmental organisations participating in the United Nations Humanitarian Response Plans, Refugee Response Plans, other United Nations appeals, or humanitarian clusters coordinated by the United Nations Office for the Coordination of Humanitarian Affairs;

(f) any grantee, subsidiary, or implementing partner of a person mentioned in sub-paragraphs (a) to (e) while and to the extent they are acting in that capacity;

Notification requirement

If you are within the scope of the UK sanctions regime and make funds or economic resources available in reliance on this exception, the Regulations require you to notify the Treasury that you are involved in the provision of humanitarian assistance activities in Syria by the end of the calendar year in which those humanitarian assistance activities take place.

However, if you are a relevant person conducting humanitarian assistance activities in Syria, assess that you may be in scope of UK sanctions and would like to be able to rely on the humanitarian exception, we suggest that you notify HMT on an annual basis that you are conducting humanitarian assistance activities in Syria regardless of whether you are certain that you need to rely on the exception and therefore whether you are required by the Regulations to do so. This suggestion aims to make it easier to comply for those who may need to rely on the exception, but are not certain that they need to do so.

Notification that a relevant person is involved in the provision of humanitarian assistance activities in Syria does not amount to confirmation that the exception has in fact been relied on, nor an admission that those activities would otherwise breach sanctions. As such, the notification does not need to confirm whether a relevant person has in fact relied on the exception and it can be made without prejudice to whether you have done so.

Suggested level of detail for notification:

• Details of the relevant person (organisation name, address, contact information)
• Confirmation that the relevant person is conducting humanitarian assistance activities in Syria for the relevant calendar year.

Please send the notification to OFSI@hmtreasury.gov.uk

The notification requirement does not apply to “relevant persons” falling under limbs (b) or (f) of the definition set out above, to humanitarian organisations having observer status with the United Nations General Assembly, or to the British Red Cross.

The Regulations include an exception from the prohibitions relating to military goods and technology, and arms and related materiel, for activities which are carried out in accordance with paragraph 10 of UNSCR 2118 (2013) to ensure the elimination of  chemical weapons in Syria.

The Regulations also provide for an exception to the restrictions on luxury goods when relating to the personal effects of a person travelling to Syria or goods of a non-commercial nature for the personal use of a person travelling to Syria and contained in that person’s luggage.

Regulation 59A establishes an exception to regulations 11 to 15 and  Chapters 2 to 5 of Part 5 (Trade)  which provides that prohibitions are not contravened if conduct is authorised by a licence which 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.

A further exception permits certain required payments to be made by, or on behalf of, designated persons to various specified UK public bodies.

The Regulations also include an exception in relation to any prohibition or requirement imposed by the Regulations for actions determined by a responsible officer 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 financial sanctions

Where a person is designated for the purposes of the financial sanctions (asset freeze measures and making available provisions) contained in the Regulations, the designated person or a representative (on their behalf) may apply for a licence from OFSI to use their funds or economic resources (non-monetary assets, such as property or vehicles). Schedule 6 to the Regulations sets out the purposes pursuant to which, or for which activities, OFSI may grant an individual licence. In summary these are:

• 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
• humanitarian assistance activities etc
• diplomatic missions etc
• human safety or environmental protection
• education, professional training or academic research
• essential energy needs
• evacuations
• extraordinary situations
• prior obligations
• insolvency

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. Should the Insolvency Service decide to grant a licence then the licence will specify the act/s it authorises. A licence may be subject to conditions. A licence may be varied or revoked, and any such changes will be communicated to any affected designated person or their authorised representative. 

You should not assume that a licence will be granted therefore you should not act as a director of a company or directly or indirectly to 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. DBT 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.

DBT has 3 licensing bodies responsible for administering licences on behalf of the Secretary of State. Which body you need to apply through is dependent on the activity you want to carry out. 

If you are carrying out activity that falls under the remit of more than one licensing body, you will need to submit separate licence applications for each one. 

DBT has produced guidance where you can check which trade licence you need. This will guide you to the application page for each type.

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 which 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.

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.

Prohibition description	Prohibition reference	Considerations for licensing
Prohibitions on the export, making available, transfer, supply or delivery of goods or technology, relating to chemical and biological weapons in Parts 1 and 2 of Schedule 3.	Regulations 29-32	A licence may be granted for the export, making available, transfer, supply or delivery of goods or technology relating to chemical and biological weapons in Parts 1 and 2 of Schedule 3 if the goods or technology are intended for humanitarian assistance activities.
		A licence may be granted for the export, making available, transfer, supply or delivery of goods or technology relating to chemical and biological weapons in Parts 1 and 2 of Schedule 3 if the goods or technology are intended for the benefit of the UK Government or the UN.
		A licence may be granted for the export, making available, transfer, supply or delivery of goods or technology relating to chemical and biological weapons in Parts 1 and 2 of Schedule 3 if it is undertaken in accordance with paragraph 10 of United Nations Security Council Resolution 2118 (2013) and related decisions of the Executive Council of the Organisation for the Prohibition of Chemical Weapons (OPCW), consistent with the objective of the Convention on the Prohibition of the Development, Production, Stockpiling and Use of Chemical Weapons and on their Destruction (Chemical Weapons Convention) and after consultation with the OPCW.
Prohibitions on the provision of technical assistance, brokering services, financial services or funds relating to goods or technology relating to chemical and biological weapons in Parts 1 and 2 of Schedule 3	Regulations 33-35	A licence may be granted for the provision of technical assistance, brokering services, financial services or funds relating to goods or technology relating to chemical and biological weapons in Parts 1 and 2 of Schedule 3 if the technical assistance, brokering services, financial services or funds are provided in relation to goods or technology which are intended for humanitarian assistance activities.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds relating to goods or technology relating to chemical and biological weapons in Parts 1 and 2 of Schedule 3 if the technical assistance, brokering services, financial services or funds are provided in relation to goods or technology for the benefit of the UK Government or the UN.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds relating to goods or technology relating to chemical and biological weapons in Parts 1 and 2 of Schedule 3 if the technical assistance, brokering services, financial services or funds are provided in relation to activities undertaken in accordance with paragraph 10 of United Nations Security Council Resolution 2118 (2013) and related decisions of the Executive Council of the OPCW, consistent with the objective of the Convention on the Prohibition of the Development, Production, Stockpiling and Use of Chemical Weapons and on their Destruction (Chemical Weapons Convention) and after consultation with the OPCW.
Prohibitions on the export, making available, transfer, supply or delivery of goods or technology relating to chemical and biological weapons in Part 3 of Schedule 3.	Regulations 29-32	A licence will not be granted for the export, making available, transfer, supply or delivery of goods or technology relating to chemical and biological weapons in Part 3 of Schedule 3 if the Secretary of State has reasonable grounds to determine that the goods or technology might be used for internal repression or for the manufacture or maintenance of anything which might be used for internal repression.
Prohibitions on the provision of technical assistance, brokering services, financial services or funds relating to goods and technology relating to chemical and biological weapons in Part 3 of Schedule 3.	Regulations 33-35	A licence will not be granted for the provision of technical assistance, brokering services, financial services or funds relating to goods and technology relating to chemical and biological weapons in Part 3 of Schedule 3 if the Secretary of State has reasonable grounds to determine that the technical assistance, brokering services, financial services or funds are intended, or may be intended, to contribute to: - internal repression, or; - the manufacture or the maintenance of anything which might be used for internal repression
Prohibitions on the export, making available, transfer, supply or delivery of interception and monitoring goods or technology.	Regulations 29-32	A licence will not be granted for the export, making available, transfer, supply or delivery of interception and monitoring goods or technology if the Secretary of State has reasonable grounds to determine that the goods or technology would be used by the Governing Authority of Syria  or on its behalf for interception and monitoring services in Syria.
Prohibitions on the provision of technical assistance, brokering services, financial services or funds relating to interception and monitoring goods or technology.	Regulations 33-35	A licence will not be granted for the provision of technical assistance, brokering services, financial services or funds relating to interception and monitoring goods or technology if the Secretary of State has reasonable grounds to determine that the provision of technical assistance, brokering services, financial services or funds relates to goods or technology that would be used by the Governing Authority of Syria or on its behalf for interception and monitoring services in Syria
Prohibitions on the export, making available, transfer, supply or delivery of internal repression goods or internal repression technology	Regulations 29-32	A licence may be granted for the export, making available, transfer, supply or delivery of internal repression goods or internal repression technology if the goods or technology are intended solely for humanitarian assistance activities or protective use.
Prohibitions on the provision of technical assistance, brokering services, financial services or funds relating to goods or technology which might be used for internal repression.	Regulations 33-35	A licence may be granted for the provision of technical assistance, brokering services, financial services or funds relating to goods or technology which might be used for internal repression if the technical assistance, brokering services, financial services or funds relate to goods or technology intended solely for humanitarian assistance activities or protective use.

When you export goods, you may need to submit an electronic export declaration via the National Export System (NES), part of His Majesty’s Revenue and Customs’ (HMRC) Customs Handling of Import and Export Freight (CHIEF) system. Guidance is available on how to make an export declaration.

Licence applications for import of goods can be made through the Apply for an import licence service, managed by DBT’s Import Licensing Branch (ILB). The DBT Import Licensing Branch will, to the extent possible, aim to inform the trader of the application outcome within 30 days. However, in some circumstances, for operational or legal reasons, DBT may need to take longer than the 30 day period. They will inform the applicant if this is the case.

When you import goods, you may need to submit an import declaration through His Majesty’s Revenue and Customs’ (HMRC) Customs Handling of Import and Export Freight (CHIEF) system. Guidance is available on how to make an import declaration.

3.5 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.

Dual-use goods and technology

Please note that the export of and trade in dual-use goods and technology are also controlled under the Dual-Use Regulation. Authorisations under that Regulation are granted by the Secretary of State for International Trade under licensing powers in the Export Control Order 2008.

This means that all licence applications relating to items which are controlled dual-use goods and technology (for instance certain items listed in Schedule 3) will also need to be considered against the Strategic Export Licensing Criteria. A licence under the Regulations is unlikely to be granted if an authorisation is refused for the same activity under the Dual-Use Regulation.

As explained above in relation to military goods and technology, only a single licence application will be required in relation to dual-use goods and technology which falls within the scope of both the Regulations and the Dual-Use Regulation. If the application is compatible with both criteria, a licence will be granted which will be valid under the Dual-Use Regulation and the Export Control Order 2008 as well as the Regulations.

Overlap between trade sanctions and financial sanctions

If you import or export goods or services, 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.

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 Syria, 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 Syria.

3.6 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

For specific queries about the sanctions regime, email: fcdo.correspondence@fcdo.gov.uk

For information about compliance with financial sanctions regulations, see Financial sanctions enforcement: case assessments and penalties. For specific queries, contact the Office of Financial Sanctions Implementation (OFSI).

To receive updates about export controls and trade sanctions, subscribe to Notices to Exporters. For specific queries about export controls and trade sanctions relating to exporting goods and providing ancillary services, contact the Export Control Joint Unit (ECJU). For information about voluntary disclosure of a trade sanctions breach, or reporting a trade sanctions breach, see Export controls: military goods, software and technology.

For information about compliance with trade sanctions regulations for professional and business services and other standalone services see Trade sanctions enforcement: case assessments and penalties. For specific queries, contact the Office of Trade Sanctions Implementation (OTSI).

You can also get help with exporting by contacting the Export Support Service.

For information on import controls and prohibitions, see Notices to importers. For specific queries, contact: importsanctions@businessandtrade.gov.uk

1. This will include the United Nations’ funds and programmes. ↩
2. This schedule includes certain dual-use items which are identified by reference to the entries in Annex I to Council Regulation 428/2009 as retained by the European Union (Withdrawal) Act 2018 (‘the Dual-Use Regulation’). ↩
3. See Regulation 33(4), 34(6) and 35(5). ↩
4. “The Assad regime” is defined in the Regulations as the regime in Syria  from 9th  May 2011 to 8th December 2024 led by Bashar Al-Assad and includes its public bodies, corporations or agencies, or any person who acted on its behalf or at its direction.
5. “Governing Authority of Syria” means
   1. the transitional Syrian authorities formed on 8 December 2024 and any successor authorities appointed thereto;
   2. the Central Bank of Syria;
   3. a person acting on behalf, or at the direction, of a person mentioned in sub-paragraph (a) or (b);
   4. a person who is not an individual and who is, or was, owned or controlled directly or indirectly (within the meaning of regulation 7) by a person mentioned in sub-paragraph (a) or (b).  ↩