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Urgent Notice: Licensing and Exceptions for Financial and Trade Sanctions
As part of our ongoing efforts to maintain national security and prevent serious crime in the UK and abroad, we are providing guidance on licensing and exceptions for financial and trade sanctions.
Licensing for Financial Sanctions
If you have been designated under the financial sanctions regulations and wish to use your frozen funds or economic resources, you may apply for a licence from the Office of Financial Sanctions Implementation (OFSI). The licence will permit specific activities, including:
- Meeting basic needs
- Paying reasonable professional fees for legal services
- Covering reasonable expenses associated with maintaining frozen assets
- Incurring extraordinary expenses
- Discharging prior obligations
Please note that OFSI may need to notify or seek approval from the relevant United Nations Sanctions Committee before issuing a licence. This may lengthen the processing time and in some cases prevent a licence from being granted.
Further information on exceptions and licensing grounds can be found in OFSI’s guidance, available on their website.
Licensing for Trade Sanctions
Licences may also be issued for certain trade activities that would otherwise be prohibited by the regulations. The Department for Business and Trade (DBT) has overall responsibility for trade sanctions licensing, and the Secretary of State for Business and Trade is ultimately responsible for making decisions on licence applications.
In considering licence applications, DBT will assess whether granting a licence would be consistent with the stated purposes of the sanctions regime and any relevant international law obligations. Specific circumstances in which licences may be granted include:
- Supplying small arms, light weapons, or ammunition to the United Nations or an authorized mission
- Supplying these items to security units operating under the command of the Government of Haiti, where intended for use by or in coordination with those entities and solely to further the objectives of peace and stability in Haiti
Licences granted will not permit activity in Northern Ireland that is inconsistent with EU sanctions restrictions on goods applying in Northern Ireland via the Windsor Framework.
Overlap with Strategic Export Licensing
Certain goods transiting the UK are subject to control, even if they do not leave the country. Article 17 of the Export Control Order 2008 includes a transit and transhipment exception, but this does not apply to goods destined for Haiti. A licence is required to transit or re-export goods to Haiti.
Directions in Respect of Immigration Sanctions
A travel ban under UNSCR 2653 does not apply where entry or transit is necessary for the fulfilment of a judicial process. The 2653 Sanctions Committee may also grant exceptions on a case-by-case basis, including for humanitarian need, religious obligation, or to further the objectives of peace and stability in Haiti.
If an exception is approved, individuals must apply for a visa to travel to the UK. Further information on applying for a UK visa and travelling to the UK can be found on GOV.UK.
Further Information
To stay up-to-date with the latest developments on trade sanctions, sign up to receive Notices to Exporters. You can also subscribe to OFSI’s e-alert for updates on changes to the consolidated list of financial sanctions targets.
Remember: if you are unsure whether an exception applies in your circumstances, seek independent legal advice.