Statutory guidance

Venezuela sanctions: guidance

Updated 5 December 2024

As required by section 43 of the Sanctions and Anti-Money Laundering Act 2018 (‘the Sanctions Act’), the Secretary of State for Foreign, Commonwealth and Development Affairs has provided this guidance to assist in the implementation of, and compliance with, the Venezuela (Sanctions) (EU Exit) Regulations 2019 (the ‘Regulations’), as amended from time to time.

The following instruments have made amendments to this instrument. If a consolidated version is not yet available on legislation.gov.uk, these instruments should be read alongside the original instrument:

• the Sanctions (EU Exit) (Miscellaneous Amendments) (No.2) Regulations 2020
• the Sanctions (EU Exit) (Miscellaneous Amendments) (No.4) Regulations 2020

As required by the Sanctions Act, this document contains guidance on the prohibitions and requirements imposed by the Regulations. It additionally provides guidance on best practice for complying with the prohibitions and requirements; the enforcement of them; and circumstances where they do not apply.

This document is intended to be read alongside more detailed sanctions guidance published by departments including the Department for Business and Trade (DBT), Home Office and HM Treasury, through the Office of Financial Sanctions Implementation (OFSI). This document contains links to those key sources of sanctions guidance, which will be regularly maintained and updated on GOV.UK. It is designed to give an overview of the prohibitions and requirements in the Regulations and, where appropriate, direct readers to further detailed guidance. This document is current on the date of publication.

1. Prohibitions and requirements imposed by the Venezuela (Sanctions) (EU Exit) Regulations 2019

The Regulations impose financial, director disqualification, trade and immigration sanctions for the purposes of encouraging the Government of Venezuela to respect democratic principles and institutions, the separation of powers and the rule of law; refrain from actions, policies or activities which repress civil society; participate in negotiations with its political opponents in good faith to bring about a peaceful solution to the political crisis; and comply with international human rights law and respect human rights.

In order to achieve the stated purposes, the Regulations impose a number of prohibitions and requirements. In order to enforce these, the Regulations establish penalties and offences, which are set out in detail in the corresponding report under section 18 of the Sanctions Act in relation to criminal offences.

The prohibitions and requirements imposed by the Regulations apply within the territory of the United Kingdom (UK) (including Northern Ireland) and in relation to the conduct of all UK persons wherever they are in the world. UK persons includes British nationals, as well as all bodies incorporated or constituted under the law of any part of the UK. Accordingly, the prohibitions and requirements imposed by the Regulations apply to all companies established in any part of the UK, and they also apply to branches of UK companies operating overseas.

The maritime enforcement powers contained in Part 9 of the Regulations apply in relation to British ships in international or foreign waters, ships without nationality in international waters and foreign ships in international waters.

It is prohibited to intentionally participate in any activities if you know that the object or effect of them is directly or indirectly to circumvent any of the prohibitions in the Regulations or to enable or facilitate the contravention of those prohibitions.

If you are unclear about any aspect of the Regulations, in particular about whether action you are considering taking could contravene the Regulations, you are advised to seek independent legal advice.

Prohibitions and requirements for the financial, director disqualification, trade, and immigration sanctions contained in the Regulations are set out below.

1.1 Designation of persons

The Regulations provide that the Secretary of State may designate persons for the purposes of financial , director disqualification and/or immigration sanctions if they are, or have been, involved in a relevant activity (as defined in regulation 6).

The UK Sanctions List lists the people designated under the Regulations, and details of the sanctions in respect of which they have been designated.

1.2 Financial sanctions

Asset freeze and making available provisions

The Regulations impose financial sanctions through a targeted asset freeze on designated persons and prohibitions on making funds or economic resources available. This involves the freezing of funds and economic resources (non-monetary assets, such as property or vehicles) of designated persons and ensuring that funds and economic resources are not made available to or for the benefit of designated persons, either directly or indirectly. These prohibitions also apply in relation to entities owned or controlled by a designated person.

More information on financial sanctions can be found in the OFSI guidance.

OFSI is the authority responsible for implementing the UK’s financial sanctions on behalf of HM Treasury. OFSI helps to ensure that financial sanctions are properly understood, implemented and enforced in the UK. Further information on how OFSI implements financial sanctions can be found on the OFSI pages of GOV.UK.

1.3 Director disqualification sanctions 

Where someone is designated under regulation 5 for the purpose of director disqualification sanctions under regulation 16A, this means that they are subject to the provisions of section 11A of the Company Directors Disqualification Act 1986 (CDDA) and Article 15A of the Company Directors Disqualification (Northern Ireland) Order 2002 (CDD(NI)O). 

The effect of the provision is to disqualify persons designated for this purpose under regulation 5 from being a director of a UK company or directly or indirectly taking part in or being concerned in the promotion, formation or management of a company.  

Under section 11A of CDDA (and, in Northern Ireland, under the equivalent Article 15A of CDD(NI)O), it will be an offence for a person subject to ‘director disqualification sanctions’ as set out in section 3A of the Sanctions and Anti-Money Laundering Act 2018 (SAMLA) to act as a director of a company or directly or indirectly to take part in or be concerned in the promotion, formation or management of a company, unless a licence has been issued by virtue of the powers granted in section 15(4A) of SAMLA and set out in regulation 35A.  

Companies House and the Department for the Economy (Northern Ireland) are responsible for recording information about director disqualification sanctions in their respective Disqualified Director Registers. Companies House is responsible for annotating the Companies Register and preventing registration of a disqualified director’s appointments. The Insolvency Service will assess and grant or refuse licence applications on behalf of the Secretary of State. The Insolvency Service also has the power to bring prosecutions for breaches of the legislation, and, where appropriate, to refer cases to other law enforcement agencies for potential prosecution.

1.4 Trade sanctions

The Regulations impose trade prohibitions relating to:

• military goods and military technology (as specified in Schedule 2 to the Export Control Order 2008)
• goods and technology which might be used for internal repression in Venezuela (as specified in Schedule 2 to the Regulations)
• goods and technology which might be used for the monitoring and interception of telecommunications (as specified in Schedule 3 to the Regulations)
• provision of interception and monitoring services (as defined at regulation 20) to or for the benefit of the Government of Venezuela
• provision of technical assistance, armed personnel, financial services or funds or associated brokering services to or for the benefit of the National Bolivarian Armed Forces of Venezuela (or persons acting on its behalf or under its direction) where such provision relates to military activities, or otherwise enables or facilitates the conduct of armed hostilities, in Venezuela

Technical guidance on interception and monitoring is available.

There are circumstances (set out in the relevant lists of controlled items) in which certain items are not controlled, for example when body armour or a helmet is accompanying a person for that person’s own protection. Please check the relevant lists as applicable.

Further detail on these trade prohibitions, including key terminology used, is explained below. Please have regard to the relevant legislation which contains full definitions of terms used herein.

Export of goods

The concept of ‘export’ is set out in customs legislation, but is further detailed in Paragraph 32 of Schedule 1 to the Sanctions Act, which clarifies that “export” means export from the UK, but does not capture where goods are removed to the Isle of Man from the UK.

The export prohibition in the Regulations covers export to Venezuela as well as exports that are for use in Venezuela. This means that, even if the immediate destination is not Venezuela, the prohibition may still apply. Exporters should check the ultimate end use of goods and may apply for a licence or contact the Export Control Joint Unit (ECJU) if they know or think the items may be used in Venezuela.

A sanctions licence is not required for exports of non-military goods covered by the Regulations from Northern Ireland to an EU Member State where the final destination is Venezuela. You will however have to comply with any licensing requirements that apply in the relevant EU Member State for the onward export to Venezuela. You will also have to comply with any other licensing requirements under UK export control legislation as applicable.

Supply and delivery of goods

Supply and delivery prohibitions in the Regulations prohibit a person from directly or indirectly supplying or delivering goods from a third country to a place in Venezuela. Regulation 23(4) specifies that for the purposes of this regulation, a third country is a country that is not the UK, Isle of Man or Venezuela.

Making goods and technology available

Prohibitions in the Regulations on making restricted goods or technology available (e.g. through a sale) include directly or indirectly making them available for use in Venezuela or to a “person connected” with Venezuela. Regulation 21(4) sets out when a person is to be regarded as “connected with” Venezuela (and this applies where the term is used in other trade prohibitions in this Part of the Regulations).

Transfer of technology

Prohibitions in the Regulations on the transfer of restricted technology include transfer to a place in Venezuela or a person “connected with” Venezuela.

The term ‘transfer’ is defined in Paragraph 37 of Schedule 1 to the Sanctions Act, which states that it ‘means a transfer by any means (or combination of means), including oral communication and that transfer of goods on which the technology is recorded or from which it can be derived, other than the export of such goods.’

Where restricted technology is contained within a good, it would be classified as a restricted good under the accompanying goods-related provisions. This includes information contained on USB memory devices, laptops, tablets and the like.

Technical assistance

The term “technical assistance” in relation to goods or technology is defined in regulation 21, which states that it means:

• technical support relating to the repair, development, production, assembly, testing, use or maintenance of the goods or technology, or
• any other technical service relating to the goods or technology

Prohibitions apply where the technical assistance relates to certain specified goods or technology.

The prohibitions apply to the direct or indirect provision of such technical assistance (1) to persons “connected with” Venezuela or (2) for use in Venezuela.

This means that, even if the person to whom you are providing the relevant technical assistance, is not in or “connected with” Venezuela the prohibition may still apply if the goods or technology to which the technical assistance relates are for use in Venezuela. Therefore, if you are providing technical assistance you should check whether the goods or technology may be used in Venezuela and apply for a licence or contact ECJU.

Financial services and funds related to goods and technology

‘Financial services’ refer to any services of a financial nature in many different forms including insurance and banking. Financial services include payment and money transmission services. The full definition of ‘financial services’ can be found in Section 61 of the Sanctions Act.

‘Funds’ means financial assets and benefits of every kind, including cash securities and interest. The full definition of ‘funds’ can be found in Section 60 of the Sanctions Act.

Trade sanctions prohibitions on the provision of financial services and funds apply where they relate to certain specified goods or technology.

The prohibitions in the Regulations apply to the direct or indirect provision of financial services, and the direct or indirect making available of funds to persons connected with Venezuela in pursuance of or in connection with an arrangement set out in the Regulations. This captures arrangements where the object or effect falls into one of the prohibitions, for example the export of goods or direct or indirect supply or delivery of goods.

These prohibitions also prohibit the direct or indirect provision of financial services or funds in pursuance of or in connection with specific arrangements as set out in regulation 27(3).

Brokering services

The definition of ‘brokering services’ is set out in regulation 21, which states that it means any service to secure, or otherwise in relation to, an arrangement including (but not limited to):

• the selection or introduction of persons as parties or potential parties to the arrangement
• the negotiation of the arrangement
• the facilitation of anything that enables the arrangement to be entered into, and
• the provision of any assistance that in any way promotes or facilitates the arrangement

The Regulations prohibit the direct or indirect provision of brokering services where they relate to specific arrangements. Those arrangements are set out in regulation 28.

Other service provisions

Certain other services are prohibited in the Regulations.

Provisions on interception and monitoring services are set out in regulation 29 and relate to the provision of such services to or for the benefit of the Government of Venezuela. The “Government of Venezuela” is defined as including its public bodies, corporations or agencies or any person acting on its behalf or at its direction. The definition of ‘interception and monitoring services’ is set out in regulation 20.

The Regulations also prohibit the direct or indirect provision of the following, to or for the benefit of the National Bolivian Armed Forces of Venezuela (or to any person acting on its behalf or under its direction), where such provision relates to the military activities of the recipient in Venezuela or otherwise enables or facilitates the conduct of armed hostilities in Venezuela:

a) technical assistance

b) armed personnel

c) financial services or funds, or

d) brokering services in relation to an arrangement whose object or effect is to provide, in a non-UK country any of the services mentioned in paragraphs (a) - (c)

DBT contact details

DBT has 3 licensing bodies responsible for administering licences on behalf of the Secretary of State. Which body you need to apply through is dependent on the activity you want to carry out. If you want to carry out activity which falls under the remit of more than one licensing body, you will need to submit separate licence applications to each one. 

For further information on licensing, compliance and enforcement for trade sanctions relating to standalone services, contact the Office of Trade Sanctions Implementation (OTSI). 

For further information on export controls and trade sanctions relating to the export of goods and provision of ancillary services, contact ECJU. 

For further information on import controls, contact DBT’s Import Licensing Branch at importcontrols@businessandtrade.gov.uk.

1.5 Immigration sanctions

The effect of the Regulations is to impose a travel ban on persons who are designated by the Secretary of State for the purposes of being made subject to immigration sanctions under the Sanctions Act. Such persons are excluded persons for the purposes of section 8B of the Immigration Act 1971.

Designated individuals will be refused leave to enter or remain in the UK. Any applications they make for a visa to travel to the UK, including for transit purposes, will be refused. Any foreign national who is subject to a travel ban under the Regulations, and who is currently in the UK, will have their permission to stay in the UK cancelled and steps will be taken to remove them from the UK.

If you are the subject of an immigration sanction and try to travel to the UK, carriers are required to deny you boarding.

Further information on how the Home Office deals with those who are subject to a travel ban can be found on the Home Office pages of GOV.UK.

1.6 Information and record keeping

For the purpose of the financial sanctions contained in the Regulations, Part 7 of the Regulations places obligations on relevant firms (the definition of which is set out in the Regulations) to report information to HM Treasury about known or suspected designated persons or about persons who may have breached a prohibition or failed to comply with an obligation under specified provisions of the Regulations.

It also grants powers to HM Treasury to request information from, amongst others, a designated person, including powers to request the production of documents. It also establishes offences for failing to comply with these requests (including for providing false information).

Part 7 also establishes information powers and record-keeping responsibilities in relation to the trade sanctions contained in the Regulations. It provides for offences for failing to comply with any of those requirements or intentionally obstructing an official in the excercise of those powers.

If you have obligations or responsibilities under Part 7 of the Regulations, it is important that you familiarise yourself with them. If you are unclear of your obligations or responsibilities, you are advised to seek independent legal advice.

2. How will these sanctions measures be enforced?

The Regulations make it a criminal offence to contravene the trade and financial sanctions, as well as to enable or facilitate a contravention of, or to circumvent, any of the prohibitions in the Regulations. They also prescribe the mode of trial and penalties that apply to such offences. In some cases, offences related to contraventions of prohibitions in the Regulations are contained within other legislation, such as the Customs and Excise Management Act 1979 (CEMA).

In addition to the below, further details on offences and penalties can be found in the corresponding report under section 18 of the Sanctions Act.

2.1 Financial sanctions

Breaches of financial sanctions are a serious criminal offence. Any breach of the main financial prohibitions in the Regulations is an offence that is triable either way and carries a maximum sentence on indictment of 7 years’ imprisonment or a fine (or both).

Offences under regulations 41(6) or 45 (information offences in connection with financial sanctions under the Regulations) are summary offences only and carry a maximum sentence of 6 months’ imprisonment or a fine (which in Scotland or Northern Ireland may not exceed level 5 on the standard scale) or both.

OFSI is responsible for monitoring compliance with financial sanctions and for assessing suspected breaches. It also has the power to impose monetary penalties for breaches of financial sanctions and to refer cases to law enforcement agencies for investigation and potential prosecution.

OFSI works with other parts of government, supervisory bodies and regulators to consider all cases reported to it, sharing relevant information accordingly.

If you find out that a person or organisation you are dealing with is subject to the financial sanctions detailed in the Regulations, you must immediately:

• stop dealing with them
• freeze any assets you are holding for them
• inform OFSI as soon as possible by either emailing ofsi@hmtreasury.gov.uk or by calling their general enquiries line: +44 (0)20 7270 5454

More detailed information on OFSI’s approach to compliance and enforcement can be found in Chapter 7 of OFSI’s guidance.

2.2 Director disqualification sanctions 

Breach of disqualified director sanctions is an offence under CDDA and CDD(NI)O.   

The Insolvency Service is responsible for monitoring compliance with disqualified director sanctions and for assessing suspected breaches of the main prohibitions and the licensing prohibitions. It also has the power to bring prosecutions for breaches under section 11A CDDA and refer cases to other law enforcement agencies for potential prosecution. 

Under section 13 of CDDA (and in Northern Ireland, under Article 18 of CDD(NI)O), a person guilty of acting in contravention of the new section 11A (in Northern Ireland, Article 15A of CDD(NI)O) will be liable (a) on conviction on indictment, to imprisonment for not more than 2 years or a fine, or both; and (b) on summary conviction, to imprisonment for not more than 2 years or a fine, or both; and (b) on summary conviction, to imprisonment for not more than 6 months or a fine not exceeding the statutory maximum, or both.

2.3 Trade sanctions

Any breach of the trade sanctions prohibitions in the Regulations is triable either way and carries a maximum sentence on indictment of 10 years’ imprisonment or a fine (or both). Any breach of the trade licensing provisions is also triable either way and carries a maximum sentence on indictment of 2 years’ imprisonment or a fine (or both).

OTSI,  in DBT, is responsible for monitoring compliance with trade sanctions and investigating suspected breaches in relation to:   

• providing or procuring sanctioned services 

• moving, making available, or acquiring sanctioned goods outside the UK  

• transferring, making available or acquiring sanctioned technology outside the UK   

• providing ancillary services to the movement, making available or acquisition of sanctioned goods outside the UK   

• providing ancillary services to the transfer, making available or acquisition of sanctioned technology outside the UK   

OTSI can issue warnings and use their powers to publish information about breaches, impose civil monetary penalties and refer cases to HM Revenue and Customs (HMRC) for criminal investigation. OTSI can also report individuals and businesses to their regulator, if they have one, and share information with organisations such as Companies House or the Insolvency Service.   

Trade sanctions apply to:   

• all individuals or businesses within the territory and territorial sea of the UK   

• all UK nationals or UK businesses established under UK law, wherever they are in the world   

This means OTSI can investigate suspected breaches committed by:   

• individuals and legal entities who are within, or undertake activities within, the UK’s territory   

• UK individuals and legal entities established under UK law, regardless of where in the world the breach takes place

HMRC is responsible for the enforcement of trade sanctions that fall within its remit as the UK’s customs authority and for the enforcement of trade sanctions measures that relate to strategic goods and technology. 

HMRC has a range of enforcement options available such as education, warning letters, issuing compound settlements, seizures / disruptions and in the most serious of cases, referral to the Crown Prosecution Service for consideration for prosecution. 

If you discover that there may have been a breach of any of the trade prohibitions or licensing provisions, you should report the irregularity to the appropriate authority as soon as possible. 

• report a suspected breach to HMRC using this email: exports.strategic@hmrc.gov.uk 

• report a suspected breach to OTSI using the Report a breach tool 

If the irregularity was found on an ECJU compliance audit, the compliance inspector will have informed HMRC and you are strongly advised to do the same. Guidance is available on how to make a voluntary disclosure.

3. Are there circumstances when I can get an authorisation or licence for a sanctioned activity?

Licensing and exception provisions are contained in Part 6 of the Regulations.

3.1 Exceptions

The Regulations set out exceptions to some of the sanctions prohibitions which apply within certain defined circumstances. An exception applies automatically, and does not require you to obtain a licence issued in accordance with the Regulations.

The Regulations establish exceptions relating to financial sanctions including for the crediting of a frozen account by a relevant institution (any such interest or other earnings will be frozen in accordance with the relevant legislation underpinning the asset freeze). An exception also exists from the prohibition on making funds available to a designated person, when funds are transferred to a frozen account in discharge (or partial discharge) of an obligation which arose before the recipient became a designated person.

Regulation 33A establishes an exception to regulations 11 to 15 and Chapters 2 to 4 of Part 5 (Trade) which provides that prohibitions are not contravened if conduct is authorised by a licence which is issued under the law of the Channel Islands, Isle of Man or any British Overseas Territory for the purpose of disapplying a prohibition in that jurisdiction which corresponds to the relevant prohibition.

A further exception permits certain required payments to be made by, or on behalf of, designated persons to various specified UK public bodies.

The Regulations also include an exception in relation to any prohibition or requirement imposed by the Regulations for actions which a responsible officer has determined to be in the interests of national security, or the prevention or detection of serious crime in the UK or elsewhere.

If you are unsure whether an exception applies in your circumstances, you are advised to seek independent legal advice.

3.2 Licensing for financial sanctions

Where a person is designated for the purpose of the financial sanctions (asset freeze and making available provisions) contained in the Regulations, the designated person or a representative (on their behalf) may apply for a licence from OFSI to use their funds or economic resources (non-monetary assets, such as property or vehicles). Schedule 4 to the Regulations sets out the purposes pursuant to which, or for which activities, OFSI may grant an individual license. In summary these are:

• basic needs
• reasonable professional fees for or reasonable expenses associated with the provision of legal services
• reasonable fees or service charges arising from the routine holding or maintenance of frozen funds or economic resources
• extraordinary expenses
• judicial decisions etc
• diplomatic missions
• extraordinary situations
• prior obligations
• insolvency

Further information on exceptions and licensing grounds can be found in OFSI’s guidance.

Information on licence applications and the relevant form can be found on OFSI’s GOV.UK licensing webpage.

3.3 Licensing for director disqualification sanctions 

The designated person, or their authorised representative, can make an application for a licence to the Insolvency Service. Should the Insolvency Service decide to grant a licence then the licence will specify the act/s it authorises. A licence may be subject to conditions. A licence may be varied or revoked, and any such changes will be communicated to any affected designated person or their authorised representative. 

You should not assume that a licence will be granted therefore you should not act as a director of a company or directly or indirectly to take part in or be concerned in the promotion, formation or management of a company, until your licence has been granted.

3.4 Licensing for trade sanctions

DBT has 3 licensing bodies responsible for administering licences on behalf of the Secretary of State. Which body you need to apply through is dependent on the activity you want to carry out.  

If you are carrying out activity that falls under the remit of more than one licensing body, you will need to submit separate licence applications for each one.  

DBT has produced guidance where you can check which trade licence you need. This will guide you to the application page for each type.

In making decisions on whether to grant a licence to permit something which would otherwise be prohibited under Part 5 of the Regulations, the Secretary of State will consider each application on a case-by-case basis to determine whether granting a licence would be consistent with the stated purposes of the sanctions regime and any UN or other relevant international law obligations.

For some prohibitions there are some specific activities that DBT considers are likely to be consistent with the aims of the sanctions. These are set out in the table below. If you think that your proposed activity falls within one of these specific descriptions you should make this clear and explain why you believe this to be the case in your application for a licence.

You should not assume that a licence will be granted or engage in any activities prohibited by the trade sanctions until your licence has been granted.

Prohibition description	Prohibition reference	Considerations for licensing
Prohibitions on the export, making available, transfer, supply or delivery of military goods or technology	Regulations 22 to 25	A licence may be granted for the export, making available, transfer, supply or delivery of non-lethal military goods or technology if the goods or technology are intended solely for humanitarian or protective use.
		A licence may be granted for the export, making available, transfer, supply or delivery of non-lethal military goods or technology if the goods of technology are for institution building programmes of the UK government and the United Nations (UN) or of regional and sub-regional organisations, or of crisis-management operations of the UN and the UK government or of regional and sub-regional organisations.
		A licence may be granted for the export, making available, transfer, supply or delivery of de-mining goods or technology if the goods or technology are for use in de-mining operations.
		A licence may be granted for the export, making available, transfer, supply or delivery of military goods or technology if the goods and technology are related to the maintenance of non-lethal goods or technology which might be used by the navy and coastguard of Venezuela and are intended solely for border protection, regional stability and the interception of narcotics.
		A licence may be granted for the export, making available, transfer, supply or delivery of military goods or technology where they apply either (a) to the execution of contracts concluded before 13 November 2017 or (b) to ancillary contracts necessary for the execution of such contracts. The person or entity seeking to perform the contract must have notified the Export Control Joint Unit of the contract before 21 November 2017.
Prohibitions on the provision of technical assistance, brokering services, financial services or funds relating to military goods or technology	Regulations 26 to 28	A licence may be granted for the provision of technical assistance, financial services or funds if the technical assistance, financial services or funds relate to non-lethal military goods or technology intended solely for humanitarian or protective use, or for institution-building programmes of the UN and the UK government or of regional or sub-regional organisations.
		A licence may be granted for the provision of technical assistance, financial services or funds if the technical assistance, financial services or funds relate to goods or technology intended for crisis-management operations of the UN and the UK government or of regional and sub-regional organisations.
		A licence may be granted for the provision of technical assistance, financial services or funds if the technical assistance, financial services or funds relate to de-mining goods or technology for use in de-mining operations.
		A licence may be granted for the provision of technical assistance, financial services or funds if the technical assistance, financial services or funds relate to the maintenance of non-lethal goods or technology which might be used by the navy and coastguard of Venezuela intended solely for border protection, regional stability and the interception of narcotics.
		A licence may be granted for the provision of technical assistance, brokering services, financial services or funds if the technical assistance, brokering services, financial services or funds relate to goods or technology which apply either (a) to the execution of contracts concluded before 13 November 2017 or (b) to ancillary contracts necessary for the execution of such contracts. The person or entity seeking to perform the contract must have notified the Export Control Joint Unit of the contract before 21 November 2017.
Prohibitions on the export, making available, transfer, supply or delivery of goods or technology which might be used for internal repression	Regulations 22 to 25	A licence may be granted for the export, making available, transfer, supply or delivery of goods or technology which might be used for internal repression if the goods or technology are intended solely for humanitarian or protective use.
		A licence may be granted for the export, making available, transfer, supply or delivery of goods or technology which might be used for internal repression if the goods or technology are intended for institution-building programmes of the UN or the UK government, or for crisis-management operations of the UN and the UK government or of regional and sub-regional organisations.
		A licence may be granted for export, making available, transfer, supply or delivery of de-mining goods or technology if the goods or technology are for use in de-mining operations.
		A licence may be granted for the export, making available, transfer, supply or delivery of goods or technology if the goods or technology are related to the maintenance of non-lethal goods or technology which might be used by the navy and coastguard of Venezuela and intended solely for border protection, regional stability and the interception of narcotics.
Prohibitions on the provision of technical assistance, brokering services, financial services or funds relating to goods or technology which might be used for internal repression	Regulations 26 to 28	A licence may be granted for the provision of technical assistance, financial services or funds if the technical assistance, financial services or funds relate to goods or technology non-lethal military goods or technology intended solely for humanitarian or protective use.
		A licence may be granted for the provision of technical assistance, financial services or funds if the technical assistance, financial services or funds relate to non-lethal military goods or technology intended for institution-building programmes of the UN and the UK government or of regional and sub-regional organisations.
		A licence may be granted for the provision of technical assistance, financial services or funds if the technical assistance, financial services or funds relate to goods or technology intended for crisis-management operations of the UN and the UK government or regional and sub-regional organisations.
		A licence may be granted for the provision of technical assistance, financial services or funds if the technical assistance, financial services or funds relate to de-mining goods or technology for use in de-mining operations.
		A licence may be granted for the provision of technical assistance, financial services or funds if the technical assistance, financial services or funds relate to the maintenance of non-lethal goods or technology which might be used by the navy and coastguard of Venezuela intended solely for border protection, regional stability and the interception of narcotics.
Prohibitions on the export, making available, transfer, supply or delivery of goods or technology which might be used for the monitoring and interception of telecommunications	Regulations 22 to 25	A licence will not be granted for the export, making available, transfer, supply or delivery of interception and monitoring goods or technology if the Secretary of State has reasonable grounds to determine that the goods or technology would be used for internal repression by the Government of Venezuela[footnote 1]
Prohibitions on the provision of technical assistance, brokering services, financial services or funds relating to goods or technology which might be used for the monitoring and interception of telecommunications	Regulations 26 to 28	A licence will not be granted for the provision of technical assistance, brokering services, financial services or funds related to interception and monitoring goods or technology if the technical assistance, brokering services, financial services or funds relate to goods or technology that the Secretary of State has reasonable grounds to determine would be used for internal repression by the Government of Venezuela.
Provision of interception and monitoring services	Regulation 29	A licence will not be granted for the provision of interception and monitoring services if the Secretary of State has reasonable grounds to determine that the services would be used for internal repression by the Government of Venezuela.

When you export goods, you may need to submit an electronic export declaration via the National Export System (NES), part of His Majesty’s Revenue and Customs’ (HMRC) Customs Handling of Import and Export Freight (CHIEF) system. Guidance is available on how to make an export declaration.

3.5 Overlap with strategic export licensing

Military goods and military technology

Please note that the export of and trade in military goods and military technology are also controlled under the Export Control Order 2008 and so you may also need a licence which is valid under that legislation. This means that all licence applications relating to military goods and military technology will also need to be considered against the Strategic Export Licensing Criteria. A licence under the Regulations is unlikely to be granted if a licence is refused for the same activity under the Export Control Order 2008.

The way this will work in practice is that we will consider an application for a licence which relates to activities that are licensable under both the Regulations and the Export Control Order 2008 as an application for a licence under both pieces of legislation. This means that only a single licence application is required.

The application will be considered against the relevant licensing criteria. If a licence is granted it will be valid under both the Export Control Order 2008 and the Regulations.

Overlap between trade sanctions and financial sanctions

If you import or export goods or services, you need to consider if financial sanctions apply to you. You may need a licence from OFSI as well as from ECJU, OTSI or the Import Controls Team.

Transit control

Certain goods transiting the UK are still regarded as being exported when they leave the country and are therefore subject to control. Article 17 of the Export Control Order 2008 includes a transit and transhipment exception meaning that in many situations a licence is not required. This exception does not apply to goods destined for Venezuela, meaning that a licence is required to transit goods through the UK or to tranship them in the UK with a view to re-exportation to Venezuela.

3.6 Directions in respect of immigration sanctions

If you are subject to immigration sanctions the Home Office may direct, on a case by case basis, that the sanction does not apply in particular circumstances, such as for travel to, or through, the UK for a UN sponsored meeting. You can check how to apply for a UK visa, and find further information about travelling to the UK on GOV.UK.

4. Further information

Sign up to receive Notices to Exporters for updates on trade sanctions.

To receive an email alerting you to any changes to the consolidated list of financial sanctions targets, you can subscribe to OFSI’s e-alert.

1. All references in this table to ‘The Government of Venezuela’ include its public bodies, corporations or agencies, or any person or entity acting on its behalf or at its direction. ↩