Statutory guidance

Syria sanctions: statutory guidance

Updated 25 March 2026

Introduction

This guidance is about the financial, director disqualification, trade and immigration sanctions imposed by The Syria (Sanctions) (EU Exit) Regulations 2019 (‘the Regulations’).

About the Regulations

The Regulations impose 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 ^{[footnote 1]}.

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 Syria (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2024
• the Syria (Sanctions) (EU Exit) (Amendment) Regulations 2025

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 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 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 , 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 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.

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.

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.

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  

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 23A 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)
• any thing which falls within Chapter 93 of the Goods Classification Table^{[footnote 2]}, other than military goods
• goods and technology relating to chemical and biological weapons (as specified in Schedule 3 to the Regulations^{[footnote 3]}
• 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. The Regulations contain full definitions of all terms.

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 Controls Team 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’ 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 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.

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 interception and monitoring services, contact the Office of Trade Sanctions Implementation (OTSI).

For further information on import controls and sanctions, 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.

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.

1.6 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 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 9 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 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.  

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.

The Office of Trade Sanctions Implementation (OTSI), part of DBT, is responsible for the civil enforcement of certain trade sanctions including for standalone services and the movement of goods involving UK companies or persons that do not cross the UK border. For information about how OTSI assesses breaches and the possible enforcement outcomes, see OTSI’s enforcement guidance.

3. Exceptions and licences

Exceptions and licensing provisions are contained in Part 7 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 7. 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 59A)

This exception relates to prohibitions where a person’s conduct would, in the absence of this regulation, contravene a relevant prohibition.

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 60)

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 55)

These exceptions relate to the prohibitions in regulations 11 to 13 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 55A)

This exception relates to the prohibitions in regulations 11 and 13 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.

Exceptions relating to petroleum products (regulation 57)

These exceptions relate to the prohibitions in regulations 12 to 15 about making funds or economic resources available to or for the benefit of designated persons.   

One exception applies when a diplomatic mission or consular post makes available funds or economic resources if:  

• the funds or economic resources are made available for certain purposes set out in the regulation, and
• the petroleum products are acquired exclusively for the official purposes of the diplomatic mission or consular post

A second exception applies when a ‘relevant person’ makes available funds or economic resources either to acquire, supply or deliver petroleum products or to provide funds, economic resources or financial services in relation to that, if:  

• the petroleum products are acquired, supplied or delivered exclusively for the purposes of providing a humanitarian assistance activity, and
• the relevant person is one of those listed in regulation 57 (7)

The exceptions also apply to anyone providing financial services, funds or economic resources – to the relevant persons listed – when relying on this exception. 

Notification requirement for the Syria exceptions relating to petroleum products

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 (via the Office of Financial Sanctions (OFSI)) that you are involved in the provision of humanitarian assistance activities in Syria by the end of the calendar year in which those activities take place.   

It is suggested that relevant persons conducting humanitarian assistance activities in Syria who may need to rely on the exception but are not certain whether they need to do so, notify OFSI on an annual basis. This will make compliance easier for those that do need to rely on the exception. Notification to OFSI that a relevant person is involved in the provision of humanitarian assistance activities in Syria can be done without prejudice: it does not amount to confirmation that the exception has in fact been relied on and that notification is therefore required, nor an admission that those activities would otherwise breach sanctions.

To comply with the notification requirement for this exception and see additional relevant guidance, go to Notification form for acquiring petroleum products in Syria. 

Further, the notification requirement here does not apply to relevant persons within sub-paragraph (b) or (f) of the definition contained in Regulation 57(7) or to humanitarian organisations with observer status with the United Nations General Assembly, or to the British Red Cross. 

For more information about using the petroleum exception for humanitarian assistance activities, see Supporting a secure and prosperous future for Syria: guidance for businesses and NGOs.

Trade sanctions exceptions

Exception for luxury goods for personal effects or personal use (regulation 58 (3))

This exception applies to the prohibitions in regulation 46 about the export, supply, delivery and making available of luxury goods to a person connected with Syria or to a place in Syria.

The exception applies if the goods are:

• the personal effects of a person travelling to Syria
• of a non-commercial nature for the personal use of a person travelling to Syria and contained in that person’s luggage

Exception to ensure the elimination of chemical weapons in Syria (regulation 58 (4))

This exception relates to the prohibitions in regulations 36, 38, 39 and 40 about the import, transport, transfer of military goods and technology and arms and related materiel, and related services, consigned from, in a place in or originating in Syria.

The exception applies to any activity if it is:

• carried out in accordance with paragraph 10 of UNSCR 2118 (2013) to ensure the elimination of chemical weapons in Syria

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 6 to the Regulations. 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. 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. 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. 

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.

DBT’s Import Controls team is responsible for licensing the import of (otherwise sanctioned) goods, software and technology. See guidance on how to apply for an import licence. The Import Controls team 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. 

The Office of Trade Sanctions Implementation (OTSI) can issue licences for (otherwise sanctioned) standalone trade services.

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.

See guidance on: 

• applying for an export licence 
• applying for an import licence

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.

Prohibitions	Type of consideration
Regulations 29 to 32	Considerations 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

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	Type of consideration
Regulations 33 to 35	Considerations 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

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	Type of consideration
Regulations 29 to 32	Considerations 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

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	Type of consideration
Regulations 33 to 35	Considerations 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

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	Type of consideration
Regulations 29 to 32	Considerations for the export, making available, transfer, supply or delivery of interception and monitoring goods or technology

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	Type of consideration
Regulations 33 to 35	Considerations for the provision of technical assistance, brokering services, financial services or funds relating to interception and monitoring goods or technology

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	Type of consideration
Regulations 29 to 32	Considerations for the export, making available, transfer, supply or delivery of internal repression goods or internal repression technology

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	Type of consideration
Regulations 33 to 35	Considerations for the provision of technical assistance, brokering services, financial services or funds relating to goods or technology which might be used for internal repression

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 or import goods, you may need to submit a declaration: guidance is available on 

• how to make an export declaration.
• how to make an import declaration

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. 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 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.

3.5 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.

1. ‘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. ↩

2. ‘the Goods Classification Table’ means the table so named in Annex I in Part Three of the Tariff of the United Kingdom.  ↩

3. 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’). ↩

4. ‘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).   ↩