On 5 February 2019, the HM Treasury and the Office of Financial Sanctions Implementation (OFSI) published general guidance on financial sanctions (available here). While the guidance is not yet in force (the March 2018 guidance, available here, is still currently in force), it will apply if the UK leaves the EU on a no-deal basis. A recurring theme in the newly published guidance has been the removal of general references to EU sanctions and listings,…

On 12 February 2019, as part of the UK Government’s Brexit planning, the Department for International Trade published the Trade etc. in Dual-Use Items, Firearms and Torture etc. Goods (Amendment) (EU Exit) Regulations 2019 (the “Regulation”), which is available here. This is the latest draft statutory instrument published by the Department for International Trade which amends export control legislation in order to prepare for the UK’s exit from the EU. The first of these instruments…

On 1 February 2019, as part of the UK Government’s planning for a No Deal Brexit outcome, the UK Government published guidance relating to its sanction policy if the UK leaves the EU without a deal (available here). If the UK leaves the EU without a deal after March 2019, all EU sanctions will be carried over through new legislation, in the form of regulations, made under the Sanctions and Anti-Money Laundering Act 2018 (the…