Somalia sanctions: guidance

The UK government has published a revised Somalia sanctions: guidance accompanying the Somalia (Sanctions) (EU Exit) Regulations 2020 (SI 2020/642). The regulations set out a targeted sanctions framework thereby transposing the sanction measures of the United Nations Security Council towards Somalia. Latter primarily contain an arms embargo and related trade and financial restrictions.
With this guidance now, the government aims to support firms in their efforts to comply with the regulations. It thereby covers the following issues, among others:
(1) the purpose and scope of the regulations;
(2) the prohibitions made by the regulations and the implications for UK firms (what do they have to look out for, which actions are disallowed);
(3) licenses under the regulation and how to obtain such license (a license must be applied for, if permission is sought to conduct an activity that would otherwise be prohibited by the regulation);
(4) recordkeeping and reporting requirements of UK firms in this context; and
(5) enforcement actions by UK government agencies to ensure compliance with the regulations.
The guidance is quite comprehensive and provides a good insight into the purpose of the regulation and the issues, UK financial market participants must consider in the context of Somalia sanctions.
This latest revised version contains updates to reflect the adoption of new Resolution 2664 (2022) by the United Nations Security Council which was passed on December 9, 2022 and which permits exemptions from sanction measures for certain humanitarian activities and / or activities to meet basic human needs. The UK government subsequently passed a new Statutory Instrument (SI 2023/121), the „Sanctions (Humanitarian Exception) (Amendment) Regulations 2023“, to transpose this new UN Resolution 2664 into UK law (please see Event ID 19507 in this context for more information). The new guidance now discusses related licensing and exemption provisions.