UK Sanctions Guide: What businesses need to know
(S) The UK operates its own policy and lists on Sanctions. Businesses need to be aware of not one but TWO lists to manage compliance. We present these.
Introduction
The UK operates sanctions regulations, which must be read and understood, to ensure compliance. What are these UK sanctions lists and what people, entities and ships are designated or specified and why? Also, discover what businesses can do to protect themselves from sanctions violations.
The law: SAMLA
The UK sanctions regimes came fully into force under the Sanctions and Anti-Money Laundering Act 2018 (the Sanctions Act) at 11 pm on 31 December 2020. The regulations establishing these regimes apply in the whole of the UK, including in Northern Ireland. Some of these regimes contain sanctions measures (for instance asset-freezes or travel bans) that apply in respect of persons or ships which have been designated or specified.
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SAMLA 20218 UK
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Publicising sanctions decisions
When the UK government makes a decision to make, vary or revoke a designation or ship specification, it will update the UK sanctions list in accordance with the publicity provisions in the relevant sanctions regulations.
Sanction List 1: The UK sanctions list
The UK government publishes the UK sanctions list, which provides details of those designated under regulations made under the Sanctions Act. The list also details which sanctions measure apply to these persons or ships, and in the case of UK designations, provides a statement of reasons for the designation.
Download the list:
Get the latest version: https://www.gov.uk/government/publications/the-uk-sanctions-list
Sanction List 2: The OFSI Consolidated List of Financial Sanctions Targets
This lists of all those subject to financial sanctions imposed by the UK, which it keeps updated. Get The OFSI Consolidated List of Financial Sanctions:
See also: https://sanctionssearch.ofsi.hmtreasury.gov.uk/
Organizations should ensure they are checking the correct list, and some may need to check both.
HM Treasury’s Office for Financial Sanctions
HM Treasury’s Office for Financial Sanctions Implementation provides a consolidated list of persons and organisations under financial sanctions, including those under the Sanctions Act and other UK legislation.
Businesses can find out
a) Who is subject to financial sanctions
b) How to challenge a sanctions decision
Who is in charge?
The UK’s licensing authorities are:
HMT Office of Financial Sanctions Implementation (OFSI) for asset freezes and other financial measures (OFSI@hmtreasury.gov.uk); The Office of Financial Sanctions Implementation (OFSI) helps to ensure that financial sanctions are properly understood, implemented and enforced in the United Kingdom. It enables financial sanctions to make the fullest possible contribution to the UK’s foreign policy and national security goals. It also helps to maintain the integrity of, and confidence, in the UK financial services sector. OFSI is part of HM Treasury.
DIT Import Licensing Branch for import measures (ilb@trade.gov.uk)
DIT Export Control Joint Unit for export and all other trade measures (help@trade.gov.uk)
DfT Transport Sanctions team for transport measures (transportsanctions@dft.gov.uk)
Links
https://www.gov.uk/government/publications/the-uk-sanctions-list
https://www.gov.uk/government/collections/uk-sanctions-regimes-under-the-sanctions-act