With sanctions very much in the news at the moment in the context of the Iran nuclear deal, the Office of Financial Sanctions Implementation (OFSI) has produced a timely factsheet offering information and advice in relation to arms embargoes, trade sanctions and financial sanctions.
Having to comply with the various types of sanctions imposed by the UN, the EU, the UK and others can be difficult for both importers and exporters, OFSI agrees.
To help affected businesses, the 11-page question-and-answer style guide (which can be found at assets.publishing.service.gov.uk) aims to answer questions relevant to those involved in importing and exporting goods and services, especially in areas where financial sanctions are in force.
The publication addresses general questions about financial sanctions, such as “Should I consider financial sanctions when importing to or exporting from the UK?”.
Not surprisingly, the answer is “yes”, with the advice being to consider not only who and where the goods or services are coming from or going to, but also who is shipping them (is a sanctioned vessel being used?), and whether a designated person is subject to financial sanctions even though they are located outside the country in which your business is operating.
In relation to licensing, the guide considers whether an OFSI licence is required if a business already has an export or trade control licence (the short answer is “you may do”), and what OFSI licensing grounds might apply to importers and exporters.
Questions about financial sanctions along the export chain are also considered, including “Do financial sanctions apply to import and export agents?”. With agents such as couriers, express operators and freight forwarders being responsible for their own due diligence, the answer is again “yes”.
Finally, financial sanctions breaches and penalties are covered and there is also a section on sources of further information.
Find out more about sanctions, embargoes and restrictions here.
