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Changes to UK sanctions regulations – overview for firms
We are writing to give you notice of changes made to the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026. The regulations have now come into force.
What’s changed
Changed relevant firms reporting from euros to pounds
- Across all UK sanctions regulations, the definitions of high value dealers and art market participants within the relevant firms regulations are updated so that monetary thresholds are expressed in pounds sterling (£) rather than euros (€). In particular, the €10,000 threshold is being replaced with a £10,000 threshold.
- This aligns sanctions reporting obligations with upcoming changes to those in the UK money laundering regulations, so firms are not reporting in two different currencies.
Electronic notices for licences
- The law has been updated to confirm that OFSI and other authorities can send notices for licences electronically without needing consent for this approach. This reflects how communications already work and removes an outdated technical requirement.
HM Treasury debt exception
- A clarification that the exception for Treasury debt applies to all transfers of funds across the entire payment chain, including intermediaries.
Updates to the prior obligations licensing ground
- The SI broadens the prior obligations licensing ground, giving OFSI greater flexibility to license legitimate pre-designation obligations in appropriate cases while maintaining safeguards against sanctions circumvention.
FAQs updated
Further information can be found here
Here are the updated Frequently-Asked Questions:
137. If I am a HVD carrying out a transaction over the value of £10,000 via card transaction, am I exempt from reporting requirements?
If you are a HVD, the relevant firm reporting requirement applies only when you make/ receive a payment (or payments) in cash of at least £10,000. This therefore does not include payments via bank transfer or digital payments.
Amended on: 12 May 2026
138. If I am an AMP carrying out a transaction over the value of £10,000 via card transaction, am I exempt from reporting requirements?
If you are an AMP, the reporting requirement applies regardless of how the transaction (or series of linked transactions) is made, where the transaction has a value of £10,000 or more.
Amended on: 12 May 2026
and the new one:
185. The Prior Obligations licensing ground has been amended by The Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026. What has changed in practice?
The prior obligations licensing ground enables payments or transfers to satisfy obligations that arose before a person was designated under financial sanctions. The Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 amended this ground so that it is now applicable to a broader range of scenarios.
In practice, this expands the range of situations in which OFSI may consider licensing payments to satisfy prior obligations, subject to a case-by-case assessment. The change comes into force from 12 May 2026.
Under the amended ground:
- It is no longer a condition that the funds or economic resources used to satisfy a prior obligation must be frozen under UK sanctions.
- The limitations on whose funds or economic resources may be used (generally, those belonging to the DP or owned or controlled entity who owes the relevant prior obligation) have also been amended.
- For DPs under UK autonomous sanctions, those limitations have been removed.
- For UN DPs, where prior obligations licensing grounds apply, those limitations have been amended to allow the prior obligations of owned or controlled entities to be satisfied using the funds or economic resources of the DP, or of other owned or controlled entities. The assets of owned or controlled entities may also be used to satisfy prior obligations of the DP, as was the case previously.
Other limitations may apply, so it is important to check a specific regime to understand what may be permitted. For example, some regime-specific amendments have been made to the Iran Nuclear, Libya and DPRK regimes. Likewise, some regimes like Afghanistan do not have a prior obligation ground at all.
The changes do not mean that all payments relating to prior obligations will be permitted. OFSI retains discretion to refuse to grant a licence which falls within the relevant prior obligations ground even when the conditions are met, or to licence only a proportion of that obligation. For more information on OFSI’s licensing processes, please refer to our guidance.
Added on 12 May 2026
Here’s where those other links lead:
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