UK’s Sanctions and Anti-Money Laundering Bill Exceptions and Licensing Policy Note: Restrictions on the movement of goods

Restrictions on the export or movement of goods and the provision of services

23. Sanctions regimes contain a wide variety of prohibitions on the export or movement of goods. Regimes also contain prohibitions on the provision of services associated with these goods, as well as on the provision of other services. The specific exceptions and/or licensing grounds will depend on the type of goods or services that each prohibition covers, as well as on the context of the regime itself.

24. In general, we intend to continue to employ the same types of licensing grounds as those in current EU regulations. The main categories of licensing grounds are:

a. Humanitarian or development goods and services: Licensing grounds for vital supplies, such as medical equipment, or the provision of services, such as technical assistance, where the restriction of such goods and services would have an adverse humanitarian impact.

b. Humanitarian or development organisations and international missions: Licensing grounds to allow the work of humanitarian organisations and international missions to continue.

c. Health and safety or the environment: Licensing grounds to allow for the provision of goods and services where there is the potential for a serious impact on human health and safety or the environment.

d. Civilian use: Licensing grounds to allow for goods and services that are exclusively for civilian use.

e. Diplomatic: Licensing grounds to allow supply of UK or other diplomatic missions protected by international law.

f. Peacekeeping missions: Licensing grounds to allow supplies for United Nations or other peacekeeping missions.

g. Media: Licensing grounds to ensure sanctions do not restrict journalists’ access to a sanctioned destination, by, for example, allowing the purchase of petrol for vehicles or the transport of protective clothing.

h. Prior contracts: In some cases, the government may wish to exempt or issues licenses for obligations under existing contracts, in order to limit undue consequences for businesses.


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