OFSI and ECJU inform about post-Brexit transition phase

The UK’s Office of Financial Sanctions Implementation (OFSI) has issued Financial Sanctions Guidance for the post-Brexit transition phase (ending on 31st December 2020). During the transition phase the UK is bound by EU sanctions, but can also bring autonomous UK sanctions into force under the Sanctions and Anti-Money Laundering Act 2018 (the Sanctions Act). This guidance document published by OFSI does not apply to financial sanctions regimes that already come under the Sanctions Act.

Additionally, the UK’s Export Control Joint Unit (ECJU) has published a notice to exporters regarding export and trade controls of strategic items. During the post-Brexit transition phase current export licensing arrangements will continue to apply and the open general export license (export of dual-use items to EU member states) will not be required to export dual-use items to the EU.