The Syria (Sanctions) (EU Exit) Regulations 2019 (S.I. 2019/792)

Summary

This is the UK Syria (Sanctions) (EU Exit) Regulations 2019 (SI 2019/792), a UK statutory instrument that recreates and continues the UK's Syria sanctions regime after Brexit, replacing the former EU Syria Regulation. It establishes designation powers, asset-freeze and trade restrictions, licensing exceptions, and reporting/enforcement mechanisms in relation to Syria. The BVI FSC has circulated it as a sanctions alert so that regulated persons in the British Virgin Islands are aware of the extended UK sanctions framework and their related compliance duties.

• Designations: The Secretary of State may designate persons involved in repressing Syria's civilian population, supporting the Syrian regime, chemical weapons activity, or circumventing the sanctions; designated persons face asset freezes and immigration exclusion.
• Asset freeze: Prohibitions on making funds or economic resources available, directly or indirectly, to or for the benefit of designated persons.
• Financial sector restrictions: Restrictions on UK credit/financial institutions regarding accounts, correspondent banking, and dealings with Syrian credit or financial institutions; restrictions on bonds, insurance/reinsurance services, and investment in Syrian crude oil and electricity production.
• Trade restrictions: Prohibitions on export, supply, transfer, import, purchase and transport of specified military goods, dual-use and chemical/biological weapons-related goods, interception and monitoring goods/technology, internal repression goods, luxury goods, gold/precious metals/diamonds, and related technical assistance, brokering and financial services.
• Interception and monitoring services: Prohibition on providing interception and monitoring services to, or for the benefit of, the Government of Syria.
• Aircraft: Power to direct that aircraft be prevented from landing in the UK where connected to the sanctions regime.
• Licensing and exceptions: Treasury, trade and aircraft licences may authorise otherwise prohibited activity; specified exceptions apply, including for national security, prevention of serious crime, interest on frozen accounts, and certain petroleum product dealings.
• Reporting and information: Relevant firms have finance reporting obligations and must respond to information/document requests; enforcement bodies (including maritime enforcement officers) have powers to stop, search and seize.

The Regulations create criminal offences for contravening or circumventing any prohibition, set penalties, and revoke the prior EU Syria Regulation and related UK instruments (SI 2012/129 and parts of SI 2013/2012). Because this is UK legislation reproduced as a BVI FSC alert, BVI-regulated entities should treat it as background on the applicable UK/overseas-territory sanctions regime rather than as a BVI-originated rule, and check current designations and licensing requirements before dealing with Syria-connected persons, goods or transactions.

Key obligations

• Do not make funds or economic resources available, directly or indirectly, to or for the benefit of any person designated under the Regulations (asset freeze).
• UK credit and financial institutions must comply with restrictions on accounts, correspondent banking relationships and dealings with Syrian credit or financial institutions.
• Do not export, supply, transfer, sell, purchase, import or transport prohibited military goods, dual-use goods, chemical/biological weapons-related goods, interception and monitoring goods/technology, internal repression goods, luxury goods, or gold/precious metals/diamonds relating to Syria without an applicable licence or exception.
• Do not provide interception and monitoring services to, or for the benefit of, the Government of Syria.
• Obtain a Treasury, trade or aircraft licence before carrying out any activity that would otherwise be prohibited under the finance, trade or aircraft provisions.
• Relevant firms must comply with finance reporting obligations under regulation 69 and provide information or documents when required under Part 8 powers.
• Do not circumvent or assist in circumventing any prohibition imposed by the Regulations.

Applies to

UK credit and financial institutions, relevant firms (as defined for finance reporting obligations), insurers and reinsurers, persons trading in specified goods and technology with Syria, aircraft operators, designated persons, Syrian credit or financial institutions

Deadlines

• the day after the day on which the Regulations are laid before Parliament: Coming into force of regulations 1, 2, 4 to 8 and Schedule 1 (citation, interpretation, purposes, designation powers and criteria).
• exit day: Coming into force of all other provisions of the Regulations, including the finance, trade, aircraft, licensing, reporting and enforcement provisions.
• twenty-eight days beginning with the day the Regulations are made (subject to extension for dissolution, prorogation or adjournment of more than four days): Period within which Parliament must approve the Regulations by resolution of each House under section 55(3) of the Sanctions and Anti-Money Laundering Act 2018.