Key frameworks amended include:

• Libya (Sanctions) (EU Exit) Regulations 2020
• South Sudan (Sanctions) (EU Exit) Regulations 2019
• Central African Republic (Sanctions) (EU Exit) Regulations 2020
• Yemen (Sanctions) (EU Exit) (No. 2) Regulations 2020
• Haiti (Sanctions) Regulations 2022 (for UN-imposed sanctions only)

The regulations aim to provide a legal basis for Treasury debt-related payments to UN-designated persons (PDs), while ensuring strict safeguards. Payments are only allowed for obligations incurred before the person’s designation and must be made to controlled accounts—such as frozen accounts or those in compliant jurisdictions—in line with UN Security Council 'prior obligations' exemptions.

A General Licence issued in October 2024 applied only to UK autonomous sanctions, limiting options for UN-designated persons. The 2025 Regulations close this gap by extending exceptions to Treasury debt payments for UN DPs, clarifying payment channels, and establishing a clear, automatic framework for legal certainty and compliance.

The amendments do not apply in respect of the UK’s Russia sanctions programme as this is not a UN-origin regime.

The regulations apply across the UK, to UK persons overseas, and in the UK’s overseas territories. They maintain the same territorial scope as the measures they amend, ensuring consistency for all UK persons as defined in sections 21(2&3) of the Sanctions and Anti-Money Laundering Act 2018.

The Sanctions (EU Exit) (Treasury Debt) Regulations 2025 can be found here and the Explanatory Memorandum here.