UK Sanctions Unit advice on preparing for the end of the transition period

The Sanctions Unit of the UK Foreign Commonwealth and Development Office has advised that, after the transition period (11pm on 31 December 2020):

• The new UK regulations and guidance will come into effect, which should be read and understood to ensure compliance;
• Only licences granted by the UK will be valid under UK sanctions legislation, and licences granted by the UK will not be recognised by the EU in respect of EU sanctions legislation;
• The UK Sanctions List covers all sanctions made under SAMLA 2018, and the OFSI Consolidated List of Financial Sanctions Targets covers all financial sanctions designations. Organisations should ensure they are checking the correct list, and some may need to check both; and
• Substantial changes will be made to the data in both lists given that UK designations will be made under a new legal framework.

The UK’s licensing authorities are:

• HMT Office of Financial Sanctions Implementation (OFSI) for asset freezes and other financial measures (OFSI@hmtreasury.gov.uk);
• 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)