Counter-Terrorism Sanctions Guidance
Summary
The UK's Office of Financial Sanctions Implementation (OFSI) has updated its guidance on Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019. Recent updates clarify new director disqualification sanctions and immigration sanctions, and strengthen OFSI's intelligence gathering and enforcement powers.
What changed
The Office of Financial Sanctions Implementation (OFSI) has issued updated statutory guidance for the Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019. Key updates reflect the Sanctions (EU Exit) (Miscellaneous Amendments) (No.2) Regulations 2024, introducing technical changes to improve intelligence gathering and enforcement capabilities, clarify licensing responsibilities, and address uncertainty in financial sanctions legislation. Notably, the guidance now incorporates information on new director disqualification sanctions and immigration sanctions, which were introduced in 2024.
Regulated entities, particularly those in the financial sector, should review the updated guidance to understand the implications of the new director disqualification measures and immigration sanctions. While the guidance itself is non-binding, compliance with the underlying regulations is mandatory. The updates aim to strengthen OFSI's ability to monitor compliance and enforce sanctions, suggesting increased scrutiny. Entities should ensure their internal policies and procedures reflect these changes to avoid potential penalties for non-compliance with the Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019.
What to do next
- Review updated guidance on Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019
- Update internal policies and procedures to reflect new director disqualification and immigration sanctions
- Ensure compliance with updated sanctions legislation
Source document (simplified)
Statutory guidance
Counter-terrorism sanctions: guidance
Guidance on the Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019
From: Foreign, Commonwealth & Development Office and Office of Financial Sanctions Implementation Published 20 March 2019 Last updated 12 March 2026
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Counter-terrorism sanctions: statutory guidance
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Details
The government has repealed Part 1 of the Terrorist Asset-Freezing etc. Act 2010 (TAFA). The Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019 came fully into force on 31 December 2020 and are intended to replace Part 1 of TAFA.
These regulations have replaced TAFA, with substantially the same effect.
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 HM Treasury, through the Office of Financial Sanctions Implementation (OFSI).
Updates to this page
Published 20 March 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.
7 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.
21 October 2024
Prior to 5 June 2024 the only sanction available for use under Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019 (“CT3”) was an asset freeze and a travel ban. On that date, in co-operation with the FCDO, The Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2024 came into force. These amended multiple regimes by introducing several new measures, including the new director disqualifications. The measure enables the relevant Minister to impose ‘Director disqualification sanctions’ meaning it will be unlawful for DPs subject to the measure to act as a director of a UK company. A DP subject to this measure will commit an offence if they ‘form a UK company, or act as a director or otherwise are involved in a company’s promotion, formation or management’.
The update to CT3’s Statutory Guidance relates to how this measure is implemented, enforced and licenced. It also details the relevant government departments involved in this new measure.
5.
16 May 2024
Guidance amended to include information about immigration sanctions.
6.
20 March 2019
First published.
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