Key Takeaways
- The Syria (Sanctions) (EU Exit) (Amendment) Regulations 2026 (SI 2026/436) came into force on 22 April 2026, removing prohibitions on gold, precious metals, diamonds and luxury goods trade with Syria.
- It is no longer prohibited to export, supply, deliver or make available gold, precious metals or diamonds to the Governing Authority of Syria, or to import or acquire these items from Syria.
- The definitions of “gold, precious metals or diamonds” and “luxury goods” were removed from the Syria (Sanctions) (EU Exit) Regulations 2019 in their entirety, along with ancillary services restrictions.
- Asset freezes on 300+ designated persons and entities remain in force, and financial services restrictions tied to the Governing Authority of Syria continue to apply.
- UK importers must still conduct designated persons checks against the UK Sanctions List before engaging in any Syria-related trade, even for previously restricted categories.
What Changed on 22 April 2026
On 22 April 2026, the UK government brought into force The Syria (Sanctions) (EU Exit) (Amendment) Regulations 2026 (SI 2026/436), amending the Syria (Sanctions) (EU Exit) Regulations 2019 (SI 2019/792). The Amendment Regulations remove the definitions of “gold, precious metals or diamonds” and “luxury goods” from the UK Syria sanctions regime in their entirety.
The practical effect is straightforward: it is no longer prohibited under UK sanctions law to:
- Export, supply, deliver or make available gold, precious metals or diamonds to the Governing Authority of Syria
- Import or acquire gold, precious metals or diamonds from the Governing Authority of Syria
- Export, supply or make available luxury goods to Syria or to a person connected with Syria
- Provide brokering, financing, funding or technical assistance services relating to these categories
The Isle of Man Treasury confirmed that the changes apply automatically to the Crown Dependency under the Sanctions (Implementation of UK Sanctions) Regulations 2019 and the Sanctions Act 2024 framework.
This change follows earlier UK sanctions easing in January 2025, when the government removed restrictions on Syrian banknotes and coinage and made 24 de-listings from the Syria sanctions list. The April 2026 amendment represents the most significant relaxation of UK Syria trade sanctions since the regime was consolidated post-Brexit.
What Was Previously Prohibited
Before 22 April 2026, the Syria (Sanctions) (EU Exit) Regulations 2019 prohibited trade in two broad categories with the Governing Authority of Syria or persons connected with Syria.
Gold, Precious Metals and Diamonds
The regulations defined “gold, precious metals or diamonds” by reference to specific HS (Harmonised System) commodity codes:
- HS 7102: Diamonds, whether or not worked, but not mounted or set
- HS 7106: Silver, including silver plated with gold or platinum, unwrought or in semi-manufactured forms
- HS 7108: Gold, including gold plated with platinum, unwrought or in semi-manufactured forms
- HS 7109: Base metals or silver, clad with gold, not further worked than semi-manufactured
- HS 7110: Platinum, unwrought or in semi-manufactured forms
- HS 7111: Base metals, silver or gold, clad with platinum, not further worked than semi-manufactured
- HS 7112: Waste and scrap of precious metal or of metal clad with precious metal
Under the previous regime, it was prohibited to export, supply, deliver or make available these items to Syria, to import or acquire them from Syria, or to provide ancillary services (brokering, financing, technical assistance) relating to such trade.
Luxury Goods
The “luxury goods” definition captured a wide range of high-value consumer items. Items previously caught included:
- Pure-bred horses
- Luxury food items above value thresholds (truffles, caviar, wine)
- Cigars above specified value thresholds
- Perfumes and cosmetics above value thresholds
- Pearls and precious stones (worked or unworked)
- Luxury vehicles
- Luxury fashion items
- Artwork and antiques
The prohibition extended to exporting, supplying or making available these goods to Syria or to persons connected with Syria. As with precious metals and diamonds, ancillary services restrictions also applied.
What Remains Restricted
Despite the removal of luxury goods and precious metals restrictions, significant elements of the UK Syria sanctions regime remain in force. UK importers and exporters must continue to comply with these restrictions.
Asset Freezes
The UK maintains asset freezes on over 300 designated persons and entities connected with the Syrian regime. The asset freeze prohibits:
- Dealing with frozen funds or economic resources owned, held or controlled by a designated person
- Making funds or economic resources available to or for the benefit of a designated person
- Engaging in actions that facilitate the circumvention of the asset freeze
The full list of designated persons is published on the UK Sanctions List and is maintained by the Office of Financial Sanctions Implementation (OFSI). This screening requirement parallels the sanctions end-use controls regime for export licensing.
Financial Services Restrictions
Restrictions on providing certain financial services to the Governing Authority of Syria remain in place. These restrictions are separate from the asset freeze and apply even where the counterparty is not a designated person.
Arms Embargo and Security-Sensitive Goods
The UK maintains an arms embargo on Syria, prohibiting the export, supply or delivery of arms and related materiel. Restrictions on security-sensitive goods and technology that could be used for internal repression also continue to apply.
Bond Restrictions
Certain bond restrictions tied to the Assad regime remain in force. These restrictions limit dealings with specific Syrian government bonds and debt instruments.
Director Disqualification and Immigration Sanctions
Designated persons remain subject to immigration sanctions (travel bans) and director disqualification measures under the UK regime. Immigration sanctions prevent designated persons from entering or remaining in the UK, and can result in deportation where the individual is already present. Director disqualification prohibits designated persons from acting as directors of UK companies or being involved in the promotion, formation or management of a UK company without court permission. These measures are designed to restrict the ability of sanctioned individuals to benefit from or operate within the UK economy. The restrictions apply automatically upon designation and remain in force until the person is de-listed by OFSI.
UK vs EU Alignment
The April 2026 amendment brings the UK Syria sanctions regime closer to alignment with the European Union, though the UK was slower to lift these particular restrictions.
The EU lifted its prohibitions on luxury goods and gold/precious metals/diamonds in February 2025, initially as a suspension and subsequently as a full repeal in a follow-up regulation. The UK retained these restrictions for an additional 14 months, maintaining the prohibitions until April 2026.
This staggered approach reflects the UK’s independent sanctions policy post-Brexit. While the UK often coordinates with international partners on sanctions decisions, it is not bound by EU regulations and makes its own determinations through the Office of Financial Sanctions Implementation (OFSI) and the Foreign, Commonwealth & Development Office (FCDO).
For UK businesses trading with EU counterparts, the alignment means that Syria-related trade in previously restricted categories is now permissible under both UK and EU law — subject, of course, to remaining restrictions on designated persons and other sanctioned activities.
Practical Implications for UK Importers
The removal of these restrictions opens opportunities for UK businesses engaged in trade with Syria. However, compliance obligations remain significant.
Due Diligence Requirements
Even though gold, precious metals, diamonds and luxury goods are no longer prohibited categories, UK importers must still:
- Screen all counterparties against the UK Sanctions List before entering into any Syria-related transaction
- Verify that no designated person is involved in the transaction chain, including beneficial owners, intermediaries, and end-users
- Document due diligence steps taken, including screening dates, search parameters, and results
- Monitor for changes — the UK Sanctions List is updated regularly, and a counterparty that is clear today could be designated tomorrow
HS Code Mapping
If you previously handled Syria trade under licence or are now considering entering this market, note that the HS codes formerly caught by the “gold, precious metals or diamonds” definition (7102, 7106, 7108, 7109, 7110, 7111, 7112) remain relevant for customs classification purposes. You can verify current commodity codes and duty rates using the UK Trade Tariff service. For commodity code classification support, tools like TariffFlow provide live HMRC verification and audit-ready classification records — useful where you need to demonstrate the correct HS code was applied for customs declarations.
Licensing No Longer Required
Prior to 22 April 2026, trade in the restricted categories with Syria would have required an OFSI licence unless a specific exemption applied. No licence is now required for trade in gold, precious metals, diamonds or luxury goods with Syria — provided no designated person is involved and no other sanctions restrictions are breached.
Record-Keeping
Maintain comprehensive records of all Syria-related transactions for at least five years. OFSI has the power to request information and documentation to verify compliance, and good records are your best defence if questions arise later. Records should include:
- Screening logs: Dates, search terms, and results of all UK Sanctions List checks performed on counterparties
- Transaction documentation: Contracts, invoices, shipping documents, and payment records for all Syria-related trade
- Due diligence notes: Evidence of counterparty verification, beneficial ownership checks, and risk assessments
- Correspondence: Email chains and meeting notes relating to Syria trade decisions and compliance reviews
How to Check Compliance
Before engaging in Syria-related trade, take these steps to verify compliance:
1. Check the UK Sanctions List
Search the UK Sanctions List for all counterparties — suppliers, buyers, intermediaries, shipping agents, and beneficial owners. The list is searchable by name, alias, and entity registration number. For exporters, this same screening applies under the dual-use goods export controls regime.
2. Review OFSI Guidance
The Office of Financial Sanctions Implementation publishes Syria sanctions guidance on GOV.UK. This guidance explains the scope of the remaining restrictions, licensing grounds (where applicable), and reporting obligations.
3. Use the Trade Tariff Service
For commodity classification and duty rate verification, use the UK Trade Tariff service. Enter the product description or HS code to confirm the correct classification and check for any remaining trade policy measures (anti-dumping, quotas, etc.) that may apply.
4. Consider Industry Guidance
Trade bodies such as the British International Freight Association (BIFA) and the Chartered Institute of Logistics and Transport (CILT) often publish sector-specific guidance on sanctions compliance. Membership can provide access to compliance updates and training.
5. Seek Legal Advice for Complex Transactions
If a transaction involves multiple jurisdictions, high values, or counterparties with complex ownership structures, consider seeking specialist legal advice. Sanctions breaches can result in significant penalties, including criminal prosecution in serious cases. Specialist counsel can help you:
- Map ownership structures: Identify beneficial owners and assess whether any designated persons have indirect control or influence
- Navigate multi-jurisdiction requirements: Ensure compliance with UK, EU and other applicable sanctions regimes where trade crosses borders
- Assess licensing needs: Determine whether any remaining restrictions require an OFSI licence or whether exemptions apply
- Respond to OFSI enquiries: Provide representation and guidance if OFSI requests information or initiates an investigation into your transactions
Frequently Asked Questions
Do I still need an OFSI licence to trade gold or luxury goods with Syria?
No. Following the entry into force of SI 2026/436 on 22 April 2026, the prohibitions on gold, precious metals, diamonds and luxury goods trade with Syria were removed. No OFSI licence is required for these categories, provided no designated person is involved and no other sanctions restrictions are breached.
What HS codes were previously restricted for Syria trade?
The HS codes formerly covered by the “gold, precious metals or diamonds” definition were: 7102 (diamonds), 7106 (silver), 7108 (gold), 7109 (base metals clad with gold), 7110 (platinum), 7111 (base metals clad with platinum), and 7112 (waste and scrap of precious metals). These codes remain valid for customs classification purposes.
How many designated persons remain on the UK Syria sanctions list?
The UK maintains asset freezes on over 300 designated persons and entities connected with the Syrian regime. The exact number fluctuates as designations are added or removed. Always check the current UK Sanctions List before transacting.
Does the sanctions relief apply to Northern Ireland?
UK sanctions apply across the United Kingdom, including Northern Ireland. The Isle of Man also confirmed that the changes apply automatically under its sanctions implementation framework. However, if your trade involves EU counterparties or routing through EU ports, verify that EU sanctions align (they do for these categories as of February 2025).
What penalties apply for sanctions breaches?
Breaches of UK financial sanctions regulations can result in monetary penalties imposed by OFSI, with maximum penalties of up to £1 million or 50% of the value of the breach (whichever is higher). In serious cases, criminal prosecution can result in imprisonment for up to seven years.
Where can I find the full text of the Amendment Regulations?
The Syria (Sanctions) (EU Exit) (Amendment) Regulations 2026 (SI 2026/436) are available on legislation.gov.uk. The GOV.UK Syria sanctions guidance page also links to the relevant statutory instruments.
Related Guidance
For broader export control requirements, see our guide to dual-use goods export controls. For understanding trade sanctions frameworks, consult our UK trade remedies explainer. For import licensing requirements, read our import licensing guide.