Context
OFSI has announced changes to the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026, which are now in force.
Key points to note
Changes to 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 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 has been 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 This reflects how communications already work and removes an outdated technical requirement.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 prior obligations licensing ground has been broadened, giving OFSI greater flexibility to license legitimate pre-designation obligations in appropriate cases while maintaining safeguards against sanctions circumvention.
FAQs updated