Counter-Terrorism International Sanctions Guidance
Summary
The UK Office of Financial Sanctions Implementation (OFSI) has updated its guidance on Counter-Terrorism (International Sanctions) Regulations 2019. Recent updates clarify legislation, strengthen intelligence gathering, and enhance enforcement powers, with specific changes reflecting the Sanctions (EU Exit) (Miscellaneous Amendments) (No.2) Regulations 2024.
What changed
The UK Office of Financial Sanctions Implementation (OFSI) has issued updated statutory guidance concerning the Counter-Terrorism (International Sanctions) (EU Exit) Regulations 2019. The latest updates, particularly those from December 5, 2024, incorporate technical changes stemming from the Sanctions (EU Exit) (Miscellaneous Amendments) (No.2) Regulations 2024. These amendments aim to improve OFSI's capacity for intelligence gathering on industry compliance, bolster enforcement powers, streamline licensing processes, and clarify existing financial sanctions legislation.
Regulated entities, including financial institutions and those involved in international trade, should review the updated guidance to ensure continued compliance with counter-terrorism sanctions. Key areas of focus include understanding the updated prohibitions and requirements, best practices for compliance and enforcement, and circumstances where sanctions do not apply. While the guidance itself is non-binding, adherence is crucial to avoid potential scrutiny and penalties. The updates also mention the addition of language regarding director disqualification measures, indicating a potential consequence for non-compliance.
What to do next
- Review updated guidance on Counter-Terrorism (International Sanctions) (EU Exit) Regulations 2019
- Ensure compliance with updated prohibitions and requirements
- Familiarize with new intelligence gathering and enforcement provisions
Source document (simplified)
Statutory guidance
Counter-terrorism international sanctions: guidance
Guidance on the Counter-Terrorism (International Sanctions) (EU Exit) Regulations 2019
From: Foreign, Commonwealth & Development Office, Export Control Joint Unit and Office of Financial Sanctions Implementation Published 3 May 2019 Last updated 12 March 2026
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Counter-terrorism international sanctions: statutory guidance
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Details
The Counter-Terrorism (International Sanctions) (EU Exit) Regulations 2019 came fully into force on 31 December 2020. They aim to further the prevention of terrorism in the UK and elsewhere by bringing together elements of several existing sanctions regimes.
This guidance assists people in implementing and complying with the regulations. It covers the prohibitions and requirements imposed and provides guidance on best practice for:
- complying with the prohibitions and requirements
- enforcing them
- circumstances where they do not apply This guidance should be read alongside more detailed sanctions guidance published by departments including the Department for Business and Trade (DBT), Home Office and HM Treasury, through the Office of Financial Sanctions Implementation (OFSI).
Updates to this page
Published 3 May 2019 Last updated 12 March 2026 show all updates
1.
12 March 2026
Page has been updated for better clarity and usability. No material changes to text.
2.
10 March 2025
Page navigation has been updated for better usability. No material changes to text.
3.
5 December 2024
These changes reflect the Sanctions (EU Exit) (Miscellaneous Amendments) (No.2) Regulations 2024 and taken together make a range of technical changes with the purpose of improving OFSI’s ability to gather intelligence on industry’s compliance with financial sanctions, strengthen OFSI’s enforcement powers, enable OFSI to conduct its licensing responsibilities more efficiently, and clarify financial sanctions legislation where there is existing uncertainty.
4.
3 October 2024
Added language for director disqualification measure.
5.
3 May 2019
First published.
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