Sanctions are imposed by governments or bodies such as the UK, US, EU and the United Nations (UN) and unilaterally by other governments to exert pressure on individuals or political regimes and for the advancement of foreign policy objectives.
Sanctions can be imposed in the form of financial or trade sanctions. Compliance with sanctions applies to both individuals and firms and a breach of sanctions legislation or regulation may be deemed to be a criminal offence, alongside civil penalties.
The UK’s Export Control Order 2008, in part, imposes requirements on UK entities with regard to the movement of controlled military goods from an overseas country to an embargoed destination, and imposes restrictions for certain prohibited goods going to any destination.
The provision of insurance and reinsurance involved in moving these goods is subject to a licence being obtained from the UK Government, without which criminal and civil penalties may ensue. This impacts on UK individuals and companies (i.e. insurers and brokers) anywhere in the world or to persons operating in the UK.
For further information relating to UK, US, EU and UN sanctions and UK Export Controls, see below:
The Foreign, Commonwealth & Development Office (FCDO), the Office of Financial Sanctions Implementation (OFSI), the Office of Trade Sanctions Implementation (OTSI), the Department for Transport (DfT), the Export Control Joint Unit (ECJU), HMRC and the National Crime Agency (NCA) implement, license and enforce sanctions legislation in the UK.
UK Sanctions List
FCDO - UK Sanctions List Search - GOV.UK
Guidance
Current UK sanctions regimes - GOV.UK
UK financial sanctions guidance - GOV.UK
UK Financial Sanctions FAQs - GOV.UK
Trade sanctions, arms embargoes, and other trade restrictions - GOV.UK
UK Maritime Services Ban and Oil Price Cap Industry Guidance - GOV.UK
Financial sanctions enforcement and monetary penalties guidance - GOV.UK
Trade sanctions: civil enforcement - GOV.UK
Export controls: military goods, software and technology - GOV.UK
Reporting
Report a suspected breach of trade sanctions - GOV.UK
Reporting information to OFSI – what to do - GOV.UK
Annual frozen asset review and reporting form - GOV.UK
Reporting sanctions evasions | FCA
The Office of Foreign Assets Control (OFAC) administer and enforce sanctions in the US.
The Bureau of Industry and Security (BIS) handle export control regulations through the Export Administration Regulations (EAR). It maintains lists like the Entity List, which restricts access to US goods and technology for certain foreign parties deemed threats to national security or foreign policy.
The Department of State also plays a role in sanctions and the Department of Justice, which prosecutes criminal breaches of sanctions laws.
US Sanctions List
Sanctions List Service | Office of Foreign Assets Control
Guidance
Home | Office of Foreign Assets Control
Sanctions Programs and Country Information | Office of Foreign Assets Control
Frequently Asked Questions | Office of Foreign Assets Control
Sanctioned Destinations under EAR
Economic Sanctions Policy and Implementation - United States Department of State
National Security Division | Export Control and Sanctions | United States Department of Justice
Reporting
The European Union administers and enforces sanctions imposed by EU legislation.
EU Sanctions List
Guidance
Sanctions (restrictive measures) - European Commission
European Union sanctions | EEAS
Reporting
The United Nations Security Council holds the authority to impose sanctions which are enforced by member states who are required to implement the sanctions imposed by the UN.
UN Sanctions List
United Nations Security Council Consolidated List | Security Council
Guidance