October 12, 2021

UK publishes updated “for information note” on counter-terrorism sanctions and export control

On October 11, 2021, the UK Office of Financial Sanctions Implementation published an updated “For information note: operating within counter-terrorism legislation, counter-terrorism sanctions and export control,” primarily aimed at International Non-Government Organizations (INGOs) that develop and provide humanitarian assistance in high-risk jurisdictions, in an effort to promote legislative compliance with counter-terrorism sanctions and export requirements without impeding legitimate humanitarian activities overseas. The “for information note” provides INGOs with a brief overview of all aspects of counter-terrorism sanctions and export control legislation and recommendations on how to comply with the legislative framework including discussions on topics such as proscription and extra-territorial jurisdiction and prosecution.  Updates include a number of changes made to sanctions and export control requirements following the implementation of the new sanctions framework under the Sanctions and Anti-Money Laundering Act 2018 as well as a new section on the “Designated Area Offence,” an offense that was introduced under the Counter-Terrorism and Border Security Act 2019.  

OFSI Press Release | OFSI Guidance – For information note: operating within counter-terrorism legislation, counter-terrorism sanctions and export control