Humanitarian Assistance Exception Notification for Petroleum Products
Summary
The UK's Office of Financial Sanctions Implementation (OFSI) has released guidance and a notification form for 'relevant persons' to report the use of a humanitarian assistance exception related to petroleum products for Syria. This exception, under the Syria (Sanctions) (EU Exit) Regulations 2019, requires notification by the end of the calendar year in which activities take place.
What changed
The UK's Office of Financial Sanctions Implementation (OFSI) has published guidance and an online notification form concerning a humanitarian assistance exception for petroleum products destined for Syria. This exception, detailed in regulation 57 of the Syria (Sanctions) (EU Exit) Regulations 2019, allows 'relevant persons' to make funds or economic resources available for the acquisition, supply, or delivery of petroleum products exclusively for humanitarian assistance activities. The guidance clarifies that notification to OFSI is required by the end of the calendar year in which such activities occur, with specific exemptions for certain entities.
Regulated entities falling within the scope of the UK sanctions regime and intending to rely on this exception must use the provided online form or the reference Word document to notify OFSI. The notification requirement is distinct from the effective date of the guidance and must be completed by the end of the calendar year in which the humanitarian assistance activity takes place. Amendments effective April 25, 2025, will narrow the scope of this exception to only apply to prohibitions related to designated persons, as prohibitions on petroleum product purchase and transport were lifted. Entities should review the regulations and the notification requirements to ensure compliance.
What to do next
- Review the Syria (Sanctions) (EU Exit) Regulations 2019, specifically regulation 57, to determine eligibility for the humanitarian assistance exception.
- If relying on the exception for petroleum products for Syria, complete and submit the OFSI notification form by the end of the calendar year in which the activities occur.
- Note the upcoming changes effective April 25, 2025, which will limit the exception's applicability.
Penalties
Failure to comply with sanctions regulations may result in penalties, though specific fines are not detailed in this guidance document.
Source document (simplified)
Guidance
Petroleum products humanitarian assistance exception: notification form
Online form for ‘relevant persons’ to notify OFSI in accordance with the exception, ‘Humanitarian assistance activity in relation to Syria (relating to petroleum products)’.
From: Office of Financial Sanctions Implementation and Foreign, Commonwealth & Development Office Published 13 March 2026 Get emails about this page Print this page This form is for certain ‘relevant persons’ relying on the humanitarian assistance exception from the prohibitions in regulations 12 to 15 under the Syria (Sanctions) (EU Exit) Regulations 2019.
This 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 exclusively for the purposes of providing a humanitarian assistance activity, and
- the relevant person is one of those listed in regulation 57 (7) For full details about the exception, see regulation 57 of the Syria (Sanctions) (EU Exit) Regulations 2019.
Notify OFSI of the use of the humanitarian assistance activity exception (relating to petroleum products) in relation to Syria
Word version of the form for reference:
Notification form for acquiring petroleum products in Syria (Word version)
MS Word Document, 40 KB
Notification requirement
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.
The notification requirement does not apply to ‘relevant persons’ falling under limbs (b) or (f) of the definition set out in regulation 57(7), to humanitarian organisations having observer status with the United Nations General Assembly, or to the British Red Cross.
Annual notification
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.
Changes in April 2025
Note that from 25 April 2025 both the exception and the notification requirement only apply in relation to the prohibitions in regulations 12 to 15 – making funds or economic resources available to, or for the benefit of, designated persons.
This is because the prohibitions on the purchase, acquisition and transport of petroleum products, and related services, were lifted in April 2025, so the exception is no longer needed in relation to those prohibitions.
Changes in 2024
The 2024 amendments to the humanitarian assistance exception to the petroleum provisions were aimed at improving the overall efficiency and usability of the exception, and included:
- expanding the list of persons eligible to rely upon it
- introducing a different notification requirement, and
- clarifying record-keeping obligations For more information, see the explanatory memorandum to the Syria (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2024.
Updates to this page
Published 13 March 2026
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