| Link(s): |
| The Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 – Explanatory Memorandum |
Context
OFSI has given advance notice of forthcoming changes made by the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026. The regulations will come into force on the 12 May 2026. The changes are outlined below.
Key points to note and next actions
Changing 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 being 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 is being 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 This reflects how communications already work and removes an outdated technical requirement.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 legislation 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.