UK Weekly Sanctions Update - Week of December 2, 2024

In this weekly update, we summarise the most notable updates in the UK sanctions world. If you have any questions in respect of any of the developments set out below, please do not hesitate to contact a member of our London Global and Government Trade team listed above.

1. Counter-terrorism (domestic) sanctions

• UK Government adds one entry to the UK sanctions list under the counter-terrorism (domestic) regime: On December 3, 2024, OFSI added Brian Anthony Sheridan to the UK sanctions list under the counter-terrorism (domestic) regime.  According to the UK Government, Mr Sheridan is "suspected of providing or assisting others in providing financial services or making available funds or economic resources for the New IRA" and this action is "the first use of the Treasury-led domestic counter terrorism financial sanctions regime targeting Northern Ireland related terrorism". (Notice_Counter_Terrorism__Domestic__031224.pdf; New Sanctions under Domestic Counter-Terrorism Regulations - GOV.UK).

2. ISIL (Da'esh) and Al-Qaida sanctions

• UK Government updates three entries on the UK sanctions list under the ISIL (Da'esh) and Al-Qaida sanctions regime: On December 5, 2024, OFSI updated the entries of Muthanna Harith Salman Al-Dari, Maysar Ali Musa Abdallah Al-Juburi and Salim Mustafa Muhammad Al-Mansur on the UK sanctions list under the ISIL (Da-esh) and Al-Qaida sanctions regime.  OFSI's amendments reflect the UN’s decision made on December 2, 2024, to amend these entries. (Notice_ISIL__Da_esh__and_Al-Qaida_051224.pdf).

3. Other sanctions

• Updates to certain UK sanctions regimes come into force:  On December 5, 2024, updates to certain UK sanctions regimes came into force pursuant to the Sanctions (EU Exit) (Miscellaneous Amendments) (No.2) Regulations 2024, which has been laid before the UK Parliament on November 14, 2024. Among other things, the new regulations: (i) changes the existing requirements on "relevant firms" and "involved persons" to report suspected offences to a requirement to report suspected breaches of sanctions regulations; (ii) creates a new insolvency licensing purpose under certain UK sanctions regimes; and (iii) introduces new civil monetary penalty powers for breaches in relation to Russia land prohibitions.  OFSI has also updated the guidance for each of the sanctions regimes updated by these new Regulations.  The Regulations also expand the definition of “relevant firms” subject to financial sanctions reporting obligations to cover high value dealers, art market participants, letting agents and insolvency practitioners with effect from 14 May 2025.  (https://ofsi.blog.gov.uk/2024/11/14/changes-to-sanctions-legislation-introduced-through-the-sanctions-eu-exit-miscellaneous-amendments-no-2-regulations-2024/).
• OFSI revokes four General Licences following introduction of “required payments” exception: On December 5, 2024, OFSI revoked four General Licences following the introduction of the required payments exception under the Sanctions (EU Exit) (Miscellaneous Amendments) (No.2) Regulations 2024, which largely came into effect on December 5, 2024.  The General Licences which were revoked were: (i) General Licence INT/2024/4836676 (which allowed certain Permitted Payments to be made by designated persons to the FCA); (ii) General Licence INT/2023/3626884 (which allowed certain Permitted Payments to be made by designated persons to Companies House); (iii) General Licence INT/2023/3781228 (which allowed certain Permitted Payments to be made by designated persons to local authorities); and General Licence INT/2024/4881897 (which allowed certain Permitted Payments to be made by designated persons to certain Revenue Authorities).  According to OFSI FAQ 130, the new required payments exception will allow for certain payments to be made from, or on behalf of, non-UN designated persons to the authorities covered by these now revoked general licences without the need for an OFSI licence. (OFSI General licence - INT/2024/4836676 Revoked - GOV.UK; OFSI General Licence INT/2023/3626884 Revoked - GOV.UK; OFSI General Licence INT/2023/3781228 Revoked - GOV.UK; OFSI General licence INT/2024/4881897 Revoked - GOV.UK; https://www.gov.uk/government/publications/uk-financial-sanctions-faqs/uk-financial-sanctions-faqs).