Vansh Gupta

This Practice Note explains the offences for failing to comply with trade sanctions under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018). It provides an introduction to the power to create offences under SAMLA 2018 and an explanation of typical scope of trade sanctions offences, information on exclusions and defences to trade sanctions breaches, including the issue of licences exempting certain activities from trade sanctions by various bodies within the Department for Business and Trade, including the Office of Trade Sanctions Implementation (OFSI). It also explains how corporate bodies can be liable for trade sanction offences as well as the maximum sentences which may be imposed following conviction for trade sanctions offences.

What are transport sanctions?Transport sanctions restrict the ownership, registration, movement and use of certain ships and aircraft. In the UK, transport sanctions are imposed by regulations made under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018), which provides the legal framework for sanctions measures, including those relating to ships and aircraft.Transport sanctions should not be understood as covering every sanctions prohibition which involves transport. A shipping or aviation transaction can also be subject to trade sanctions, financial sanctions and export controls. For example, maritime transportation of Russian oil and related services, or prohibitions on services connected with a specified ship, are imposed as 'trade measures' rather than transport sanctions under the Russia regime. See Practice Notes: Understanding the UK trade sanctions regime and Understanding the financial sanctions regime.For more information on the legislative framework under SAMLA 2018, see Practice Notes: The UK sanctions framework under SAMLA 2018 and UK sanctions regimes currently in force.What transport sanctions are currently in force?UK transport