The Foreign and Commonwealth Office (FCO) has overall responsibility for the UK's policy on sanctions and embargoes. The FCO provides an overview list of all sanctions currently in force, country by country.
These embargoes are generally imposed by the United Nations or European Union on "arms and related material" (such as, military ammunition, weapons and goods). The UK typically interprets this as covering all goods and technologies on the UK Military List. Goods that are not specifically listed, might also need a licence under the Military End-Use Control. Controls on the supply of military items between another third country and the sanctions target (trafficking and brokering) also apply.
Certain specific sanctions are imposed on dual-use goods such as petrochemicals or telecommunications items.
The key regulator for exporting and trading in controlled strategic goods (military and dual-use) and also the administration of licensable goods subject to arms embargoes is the Export Control Organisation. The ECO forms part of the Department for Business, Innovation and Skills (BIS).
Import licences apply for certain textiles, firearms, ammunition, iron and steel. There are also prohibitions on the import of anti-personnel mines, torture equipment and certain goods from Iran and North Korea.
The Import Licensing Branch (ILB) of BIS is the regulator which administers sanctions that involve a ban on importing items into the UK.
Asset freezes and other financial embargoes are administered by the Asset Freezing Unit at HM Treasury.
These are administered by the UK Visas and Immigration.
Exporting without a licence
It is a criminal offence to export, import or trade in goods that are subject to a sanctions and embargo regime without a specific licence from the appropriate Government department.
It is vital that individual traders and brokers check that their goods can be exported or traded to a particular destination, as missing or incorrect licences can lead to delays, seizures, fines, penalties, and even imprisonment.
Exporters and traders, particularly those who work in controlled sectors, eg defence manufacturing, must keep up to date with legislation, which is subject to change. You are advised to subscribe to the update notices issued by the relevant Government department including Export Control Organisation, Import Licensing Branch or HM Treasury.
If you or your business are impacted by sanctions you should seek your own legal advice.