(S,P) Information on trade sanctions, arms embargoes and trade restrictions, including trade controls, transit controls and restrictions on terrorist organisations.
Introduction
Countries use sanctions to fulfil a range of purposes, including supporting foreign policy and national security objectives, as well as maintaining international peace and security, and preventing terrorism. Sanctions measures include arms embargoes, trade sanctions and other trade restrictions.
Responsible Agency
The Foreign, Commonwealth & Development Office (FCDO) is responsible for overall UK policy on sanctions. The Department for International Trade (DIT) implements trade sanctions and other trade restrictions and has overall responsibility for trade sanctions licensing.
The UK implements a range of UK sanctions regimes through regulations established under the Sanctions and Anti-Money Laundering Act 2018 (the Sanctions Act). The Sanctions Act provides the legal basis for the UK to impose, update and lift sanctions. These regimes apply to the whole of the UK, including Northern Ireland. It is your responsibility to ensure that you are compliant with the requirements of the new legislation. 
DIT’s Export Control Joint Unit (ECJU) has overall responsibility for trade sanctions licensing. Licence applications can be made through the online export licensing system SPIRE. You can provide extra information on the activities you wish to carry out in a cover letter. You should attach this and any other documentation to the application. Contact us at tradesanctions@trade.gov.uk if you have any questions on trade sanctions licensing. For example, buying petroleum products for humanitarian relief in Syria.
DIT’s import licensing branch is responsible for implementing trade sanctions relating to imports.
Arms embargo, trade sanctions and other trade restrictions
An arms embargo is a prohibition that applies to the trade or activities related to military items. An arms embargo may be imposed by the United Nations (UN), the Organisation for Security and Co-operation in Europe (OSCE) or the UK.
Under the Sanctions Act, arms embargoes consist of prohibitions on export, supply or delivery, making available and transfer of military items and on the provision of technical assistance, financial services and funds, and brokering services related to military items.
Trade sanctions are controls on:
the import, export, transfer, movement, making available and acquisition of goods and technology
the provision and procurement of services related to goods and technology
the provision and procurement of certain other non-financial services
the involvement of UK people in these activities.
There may be specific exceptions under which it is possible to engage in an activity that would otherwise be prohibited. It may also be possible to get a licence that would permit you to engage in an activity that would otherwise be prohibited.
Trade controls
The UK also imposes trade controls on trafficking and brokering of military goods from one overseas country to another. Trade controls apply to specific activities, including brokering, that involve certain controlled goods.
Goods that are subject to trade controls are specified in category A, category B and category C, of Schedule 1 to the Export Control Order 2008, as amended.
Article 20 of the Export Control Order 2008, as amended, sets out what trade controls apply in respect of embargoed destinations. Article 20 does not apply to countries with arms embargoes made under the Sanctions and Anti-Money Laundering Act 2018.
Transit controls
Certain goods transiting the UK are regarded as being exported when they leave the country and are 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 certain goods destined for countries listed below, meaning that a licence is required to transit goods through the UK or tranship them in the UK with a view to re-exportation to these countries.
The Export Control Order 2008 includes a list of the countries which are subject to transit controls for military goods, and a list of countries which are subject to transit controls for Category B goods.
Military goods are those as listed in Schedule 2 to the Export Control Order. Category B of the controls comprises small arms and light weapons, unmanned aerial vehicles (UAVs), long-range missiles and man-portable air-defence systems.
Transit controls also apply to Category A goods for all countries.
ECOWAS restrictions
The Economic Community of West African States (ECOWAS) adopted a convention on small arms and light weapons, their ammunition and other related materials, and a moratorium on the import, export and manufacture of light weapons in June 2006. 
The UK will not issue an export licence for small arms and light weapons, components or ammunition unless the ECOWAS Commission has issued an exception to its moratorium.
Countries subject to arms embargo, trade sanctions and other trade restrictions
This list details specific countries where arms embargo, trade sanctions and other trade restrictions have been imposed. This list does not include countries subject to only financial or other types of sanctions.
List of countries:
Afghanistan (trade sanctions including an arms embargo, and transit control)
Albania (transit control)
Argentina (trade restrictions and transit control)
Armenia (arms embargo, trade controls, and transit control)
Azerbaijan (arms embargo, trade controls, and transit control)
Belarus (trade sanctions including an arms embargo, and transit control)
Benin (ECOWAS restrictions and transit control)
Bosnia/Herzegovina (transit control)
Burkina Faso (ECOWAS restrictions and transit control)
Burma (Myanmar) (trade sanctions including an arms embargo, and transit control)
Burundi (transit control)
Cameroon (transit control)
Cape Verde (ECOWAS restrictions and transit control)
Central African Republic (trade sanctions including an arms embargo, and transit control)
Chad (transit control)
China (People’s Republic other than the Special Administrative Regions) (arms embargo and transit control)
Colombia (transit control)
Congo (Brazzaville) (transit control)
Côte d’Ivoire (Ivory Coast) (ECOWAS restrictions and transit control)
Democratic People’s Republic of Korea (trade sanctions including an arms embargo, and transit control)
Democratic Republic of the Congo (trade sanctions including an arms embargo, and transit control)
Dubai (transit control)
East Timor (Timor-Leste) (transit control)
Eritrea (transit control)
Ethiopia (transit control)
Gambia (ECOWAS restrictions and transit control)
Georgia (transit control)
Ghana (ECOWAS restrictions and transit control)
Guinea (ECOWAS restrictions and transit control)
Guinea-Bissau (ECOWAS restrictions and transit control)
Haiti (transit control)
Hong Kong Special Administrative Region (arms embargo and transit control)
Iran (relating to human rights) (trade sanctions including an arms embargo, and transit control)
Iran (relating to nuclear weapons) (trade sanctions (including an arms embargo) and transit control)
Iraq (trade sanctions including an arms embargo, and transit control)
Jamaica (transit control)
Kenya (transit control)
Krygyzstan (transit control)
Lebanon (trade sanctions including an arms embargo, and transit control)
Liberia (ECOWAS restrictions and transit control)
Libya (trade sanctions including an arms embargo, and transit control)
Macao Special Administrative Region (transit control)
Mali (ECOWAS restrictions and transit control)
Mauritania (transit control)
Moldova (transit control)
Montenegro (transit control)
Morocco (transit control)
Nepal (transit control)
Niger (ECOWAS restrictions and transit control)
Nigeria (ECOWAS restrictions and transit control)
Oman (transit control)
Pakistan (transit control)
Russia (trade sanctions including an arms embargo, and transit control)
Rwanda (transit control)
Senegal (ECOWAS restrictions and transit control)
Serbia (transit control)
Sierra Leone (ECOWAS restrictions and transit control)
Somalia (trade sanctions including an arms embargo, and transit control)
Sri Lanka (transit control)
South Sudan (trade sanctions including an arms embargo, and transit control)
Sudan (trade sanctions including an arms embargo, and transit control)
Syria (trade sanctions including an arms embargo, and transit control)
Taiwan (transit control)
Tajikistan (transit control)
Tanzania (transit control)
Togo (ECOWAS restrictions and transit control)
Trinidad & Tobago (transit control)
Turkmenistan (transit control)
Uganda (transit control)
Ukraine (trade sanctions and transit control)
Uzbekistan (transit control)
Venezuela (trade sanctions including an arms embargo, and transit control)
Yemen (trade sanctions including an arms embargo, and transit control)
Zimbabwe (trade sanctions including an arms embargo, and transit control)
Non-country-specific export policies and restrictions
You need an export licence before you can export controlled goods, software, and technology from the UK to another country. This is described in Schedules 2 and 3 to the Export Control Order 2008, as amended.
For further information, you can read about licensing procedures and other restrictions for the export of:
military goods, software and technology
dual-use items, software and technology, goods for torture and radioactive sources
Restrictions applying to terrorist organisations
The UN Security Council has imposed measures against terrorist organisations in relation to financial and visa sanctions, and arms embargoes.
For more information on these restrictions, you can read about sanctions on:
ISIL (Da’esh) and Al-Qaida
international counter-terrorism sanctions
Overlap between trade sanctions and strategic export controls
Military goods and technology
Please note that the export of and other trade in military goods and technology is controlled under sanctions regulations and the Export Control Order 2008, and so you may need a licence which is valid under both pieces of legislation.
This means that all licence applications relating to military goods and technology will need to be considered against the sanctions licensing purposes, and the strategic export licensing criteria. A licence under sanctions 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 sanctions regulations and the Export Control Order 2008 as an application 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 sanctions regulations.
Breaching trade sanctions and export controls is a criminal offence. Find information on how to report a breach of trade sanctions.
Overlap between trade sanctions and financial sanctions
If you trade in goods or services, you need to consider if financial sanctions apply to you. For instance, where your licensable trade activity may also involve making funds or an economic resource available to, or for the benefit of, a designated person.
The Office of Financial Sanctions Implementation (OFSI) is responsible for the implementation and administration of international financial sanctions in the UK. You may need a licence from OFSI as well as from the Export Control Joint Unit.
Other non-trade-related restrictions
There are various non-trade-related restrictions in force that relate to UK exports, such as immigration sanctions, financial sanctions. The FCDO is responsible for the overall UK policy on international sanctions. You can find information on other types of sanctions on the UK sanctions guidance page.
Further information
For general guidance on export controls and trade sanctions, contact the Export Control Joint Unit (ECJU):
Email: exportcontrol.help@trade.gov.uk Helpline: +44 (0)20 7215 4594
For general guidance on import controls and trade sanctions contact: importcontrols@trade.gov.uk
For general information on sanctions email the Foreign, Commonwealth and Development Office’s Sanctions Unit on: sanctions@fcdo.gov.uk
For information on financial sanctions, contact the Office of Financial Sanctions Implementation on OFSI@hmtreasury.gov.uk or subscribe to OFSI’s e-alerts
For further information on immigration sanctions: contact the Home Office on public.enquiries@homeoffice.gov.uk
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