UK’s Sanctions and Anti-Money Laundering Bill Exceptions and Licensing Policy Note: Counter Terrorism & Restrictions on financial activities

Counter terrorism

 

21. We intend to operate the same licensing arrangements for domestic counter-terrorism sanctions as we currently do under section 17 of the Terrorist Asset Freezing Act 2010 (TAFA). It is important to remember that domestic counter-terrorism sanctions have a different focus to other sanctions regimes, in that they aim to manage the risk of terrorist financing, predominantly in cases of individuals located within the UK, to prevent terrorist financing risks manifesting within the UK. Greater flexibility in licensing better enables us to manage the terrorist financing risk posed by each licence request.

Restrictions on financial activities and investment

22. Some sanctions regimes contain prohibitions on financial activities and investment, as well as on the ownership and control of entities. In general, we intend to continue to employ the same types of licensing grounds and authorisations as those in current EU regulations, for example:

a. Prior contracts: In some cases, the government may wish to exempt or issue licences for obligations under existing contracts to limit undue consequences for businesses.

b. Civilian projects: Licensing grounds to allow for investment, ownership or control of entities undertaking projects exclusively for the benefit of the civilian population.

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