The Central African Republic (Sanctions) (EU Exit) (Amendment) Regulations 2025

Published: Tue 16th Dec 25

The Central African Republic (Sanctions) (EU Exit) (Amendment) Regulations 2025 update the existing 2020 sanctions framework concerning the Central African Republic to incorporate amendments mandated by United Nations Security Council Resolutions 2745 (2024) and 2789 (2025).

These amendments primarily introduce new definitions for "armed group operating in the Central African Republic" and "associated individual" and subsequently amend provisions concerning the arms embargo, export of military goods, provision of technical assistance, financial services, and brokering activities to target these non-state actors directly, ensuring the UK's sanctions regime reflects its international obligations.

Arguments For

Supports the UK's commitment to international obligations by transposing recent United Nations Security Council resolutions (2745 and 2789) into domestic law.
Modernizes existing sanctions by specifically targeting 'armed groups operating in the Central African Republic' and their 'associated individuals' rather than solely focusing on the Government of the Central African Republic or geographic locations, potentially increasing the effectiveness of targeted restrictions.
Maintains consistency with prior legislative actions under the Sanctions and Anti-Money Laundering Act 2018 by exercising appropriate powers to amend retained EU sanctions measures post-Brexit.
Clarifies and strengthens prohibitions related to military goods, technical assistance, and financial services by explicitly linking them to these newly defined non-state actors.

Arguments Against

Implementation requires updating compliance procedures for businesses dealing with Southern African trade or finance, potentially increasing administrative burdens and compliance costs.
The definitions for "armed group operating in the Central African Republic" and "associated individual" are broad, which could lead to uncertainty regarding which entities or persons fall under direct sanctions, potentially capturing legitimate actors unintentionally.
The regulation amends sanctions already in place (the 2020 Regulations), suggesting a continuous evolution of bespoke post-Brexit sanctions, which can create complexities for legal interpretation over time.
Reliance on evolving UN resolutions necessitates constant monitoring of international developments to ensure continuous compliance.

The Secretary of State, considering that the condition in section 45(2) of the Sanctions and Anti-Money Laundering Act 2018 is met, makes the following Regulations in exercise of the powers conferred by sections 1(1)(a) and (3)(a), 5, 11(5), 17(4), 54(2), 62(4)(d) of, and paragraphs 2(a)(iii), 4(a)(iii), 5(a)(iii), 6(a)(iii), 11(a)(iii), 13(a), (g), (k), (m), (u) and (w) and 14(a) and (f) of Schedule 1 to, that Act.

The Secretary of State issues these Regulations based on the authority granted by specific sections and schedules of the Sanctions and Anti-Money Laundering Act 2018, confirming that the necessary preconditions under section 45(2) of that Act have been satisfied for making these specific amendments.

Citation, commencement and extent1.

(1)

These Regulations may be cited as the Central African Republic (Sanctions) (EU Exit) (Amendment) Regulations 2025.

(2)

These Regulations come into force on 6th January 2026.

(3)

These Regulations extend to England and Wales, Scotland and Northern Ireland.

This section identifies the official title of the legislative instrument as the Central African Republic (Sanctions) (EU Exit) (Amendment) Regulations 2025.

It specifies that the rules become legally effective on January 6th, 2026, and confirms that the regulations apply across the entire United Kingdom, covering England, Wales, Scotland, and Northern Ireland.

Amendments to the Central African Republic (Sanctions) (EU Exit) Regulations 20202.

(1)

The Central African Republic (Sanctions) (EU Exit) Regulations 2020 are amended in accordance with this regulation.

(2)

In regulation 2 (interpretation), after the definition of “resolution 2507” insert—

““resolution 2536” means resolution 2536 (2020) adopted by the Security Council on 28 July 2020;
“resolution 2588” means resolution 2588 (2021) adopted by the Security Council on 29 July 2021;
“resolution 2648” means resolution 2648 (2022) adopted by the Security Council on 29 July 2022;
“resolution 2693” means resolution 2693 (2023) adopted by the Security Council on 27 July 2023;
“resolution 2745” means resolution 2745 (2024) adopted by the Security Council on 30 July 2024;
“resolution 2789” means resolution 2789 (2025) adopted by the Security Council on 29 July 2025;”.

(3)

In regulation 4 (purposes)—

(a)

in paragraph (3)(c) for “paragraph 54 of resolution 2127” substitute “paragraph 2 of resolution 2745;

(b)

in paragraph (4)(f) omit “and”;

(c)

after paragraph (4)(g) insert—

(h)
paragraph 5 of resolution 2536;
(i)
paragraph 5 of resolution 2588;
(j)
paragraph 5 of resolution 2648;
(k)
paragraph 5 of resolution 2693;
(l)
paragraph 5 of resolution 2745; and
(m)
paragraph 1 of resolution 2789.”;

(d)

after paragraph (4) insert—

(5)
Any reference to the obligations that the United Kingdom has by virtue of paragraph 2 of resolution 2745 (arms embargo) is to that provision read with paragraph 1 of resolution 2789.”.

(4)

In regulation 6 (designation criteria: meaning of “involved person”), in sub-paragraph (5)(c) for “and 2507” substitute “, 2507, 2536, 2588, 2648, 2693, 2745 and 2789”.

(5)

In regulation 20 (interpretation of other expressions used in this Part), for paragraph (4) substitute—

(4)
For the purposes of this Part, a group is to be regarded as an “armed group operating in the Central African Republic” if the group is—
(a)
party to an armed conflict in the Central African Republic, and
(b)
not acting on the instructions of, or under the direction or control of, the Government of the Central African Republic.
(5)
For the purposes of this Part, an “associated individual” includes an individual who—
(a)
is a member of an armed group operating in the Central African Republic; or
(b)
takes part in any activities that the individual knows or reasonably suspects are activities of the armed group or will help the armed group carry out its activities.”.

(6)

In regulation 21 (export of military goods), in paragraph (1), for “, or for use in, the Central African Republic” substitute “an armed group operating in the Central African Republic or an associated individual”.

(7)

In regulation 22 (supply and delivery of military goods)—

(a)

in paragraph (1), for “a place in the Central African Republic” substitute “an armed group operating in the Central African Republic or an associated individual”;

(b)

in paragraph (3), for “the Central African Republic” substitute “an armed group operating in the Central African Republic or an associated individual”.

(8)

In regulation 23 (making military goods and military technology available)—

(a)

for paragraph (1) substitute—

(1)
A person must not directly or indirectly make military goods or military technology available to an armed group operating in the Central African Republic or an associated individual.”;

(b)

for paragraph (3) substitute—

(3)
A person (“P”) who contravenes the prohibition in paragraph (1) commits an offence, but it is a defence for P to show that P did not know and had no reasonable cause to suspect that the armed group was operating in the Central African Republic or that the individual was an associated individual.”.

(9)

In regulation 24 (transfer of military technology)—

(a)

for paragraph (1) substitute—

(1)
A person must not transfer military technology to an armed group operating in the Central African Republic or an associated individual.”;

(b)

for paragraph (3) substitute—

(3)
A person (“P”) who contravenes the prohibition in paragraph (1) commits an offence, but it is a defence for P to show that P did not know and had no reasonable cause to suspect that the transfer was to an armed group operating in the Central African Republic or an associated individual, or that the individual was an associated individual.”.

(10)

In regulation 25 (technical assistance relating to military goods and military technology)—

(a)

for paragraph (1) substitute—

(1)
A person must not directly or indirectly provide technical assistance relating to military goods or military technology to an armed group operating in the Central African Republic or an associated individual.”;

(b)

for paragraph (3) substitute—

(3)
A person (“P”) who contravenes the prohibition in paragraph (1) commits an offence, but it is a defence for P to show that P did not know and had no reasonable cause to suspect that the armed group was operating in the Central African Republic or that the individual was an associated individual.”.

(11)

In regulation 26 (financial services and funds relating to military goods and military technology)—

(a)

in paragraph (1) for “a person connected with the Central African Republic” substitute “an armed group operating in the Central African Republic or an associated individual”;

(b)

in paragraph (2) for “a person connected with the Central African Republic” substitute “an armed group operating in the Central African Republic or an associated individual”;

(c)

in paragraph (3)(a) for “, or for use in, the Central African Republic” substitute “an armed group operating in the Central African Republic or an associated individual”;

(d)

in paragraph (3)(b) for “a place in the Central African Republic” substitute “an armed group operating in the Central African Republic or an associated individual”;

(e)

for paragraph (3)(c) substitute—

(c)
directly or indirectly making military goods or military technology available to an armed group operating in the Central African Republic or an associated individual,”;

(f)

for paragraph (3)(d) substitute—

(d)
the transfer of military technology to an armed group operating in the Central African Republic or an associated individual, or”;

(g)

for paragraph (3)(e) substitute—

(e)
the direct or indirect provision of technical assistance relating to military goods or military technology to an armed group operating in the Central African Republic or an associated individual.”;

(h)

for paragraph (5)(a) substitute—

(a)
it is a defence for a person charged with an offence of contravening paragraph (1) or (2) (“P”) to show that P did not know and had no reasonable cause to suspect that the armed group was operating in the Central African Republic or that the individual was an associated individual.”.

(12)

In regulation 27 (brokering services: non-UK activity relating to military goods and military technology)—

(a)

in paragraph (1)(a) for “a place in the Central African Republic” substitute “an armed group operating in the Central African Republic or an associated individual”;

(b)

for paragraph (1)(b) substitute—

(b)
directly or indirectly making military goods available in a third country for direct or indirect supply or delivery to an armed group operating in the Central African Republic or an associated individual,”;

(c)

for paragraph (1)(c) substitute—

(c)
directly or indirectly making military technology available in a third country for transfer to an armed group operating in the Central African Republic or an associated individual,”;

(d)

for paragraph (1)(d) substitute—

(d)
the transfer of military technology from a place in a third country to an armed group operating in the Central African Republic or an associated individual,”;

(e)

for paragraph (1)(e) substitute—

(e)
the direct or indirect provision, in a non-UK country, of technical assistance relating to military goods or military technology to an armed group operating in the Central African Republic or an associated individual,”;

(f)

in paragraph (1)(f)(i) for “a person connected with the Central African Republic” substitute “an armed group operating in the Central African Republic or an associated individual”;

(g)

in paragraph (1)(g) for “a person connected with the Central African Republic” substitute “an armed group operating in the Central African Republic or an associated individual”.

(13)

In regulation 28 (enabling or facilitating the conduct of armed hostilities)—

(a)

for paragraph (1) substitute—

(1)
A person must not directly or indirectly provide anything falling within paragraph (1A) to or for the benefit of an armed group operating in the Central African Republic or an associated individual, or to any person acting on behalf or under the direction of such an armed group or associated individual, where such provision—
(a)
relates to the operations of the recipient in the Central African Republic, or
(b)
otherwise enables or facilitates the conduct of armed hostilities in the Central African Republic.”;

(b)

after paragraph (1) insert—

(1A)
The following fall within this paragraph—
(a)
technical assistance,
(b)
armed personnel,
(c)
financial services or funds, or
(d)
brokering services provided in relation to an arrangement whose object or effect is to provide, in a non-UK country, anything mentioned in sub-paragraphs (a) to (c).”;

(c)

for paragraph (3) substitute—

(3)
A person who contravenes the prohibition in paragraph (1) commits an offence, but it is a defence for a person charged with that offence (“P”) to show that P did not know and had no reasonable cause to suspect that—
(a)
the provision as mentioned in paragraph (1)—
(i)
was to or for the benefit of an armed group operating in the Central African Republic or an associated individual, or to any person acting on behalf or under the direction of such a group or individual;
(ii)
related to the operations of the recipient in the Central African Republic or would otherwise enable or facilitate the conduct of armed hostilities in the Central African Republic; or
(b)
the individual to whom the provision as mentioned in paragraph (1) was made was an associated individual.”.

This main section details the amendments made to the principal legislation, the Central African Republic (Sanctions) (EU Exit) Regulations 2020.

Subsection (2) updates the interpretation definitions in Regulation 2 by inserting definitions for resolutions 2536, 2588, 2648, 2693, 2745, and 2789, adopted by the UN Security Council between 2020 and 2025.

Subsection (3) amends Regulation 4 regarding the purposes of the sanctions.

It updates references to Resolution 2127 to Resolution 2745 in relation to the arms embargo and expands the list of relevant Security Council resolutions that inform the purpose of the sanctions.

Subsection (4) updates the criteria for designating an 'involved person' under Regulation 6 to include references to the new UNSC resolutions.

Subsection (5) substantially rewrites Regulation 20 to define two critical terms: an "armed group operating in the Central African Republic" (defined as a party to an armed conflict within the CAR that is not directed by the CAR Government) and an "associated individual" (a member of such a group or someone assisting its activities).

The subsequent subsections (6) through (13) systematically replace references to "the Central African Republic," "a place in the Central African Republic," or "a person connected with the Central African Republic" with references to the newly defined "armed group operating in the Central African Republic or an associated individual" across regulations covering the export, supply, transfer, technical assistance, financial services, brokering, and general enablement of armed hostilities.

Stephen Doughty

Minister of State

Foreign, Commonwealth and Development Office

15th December 2025

Explanatory Note

(This note is not part of the Regulations)

These Regulations are made under the Sanctions and Anti-Money Laundering Act 2018 (c. 13) to amend the Central African Republic (Sanctions) (EU Exit) Regulations 2020 (S.I. 2020/616) (“the CAR Regulations”). These amendments are being made to ensure compliance with the UK’s UN obligations, specifically to ensure changes made by the UN Security Resolution 2745 (2024) (as extended by Resolution 2789 (2025)), in relation to the Central African Republic, are reflected.

Regulation 4 of the CAR Regulations is amended to include reference to the amendment of the scope of the arms embargo by Resolution 2745 (2024) in relation to armed groups and associated individuals operating in the Central African Republic. Regulation 20 of the CAR Regulations is amended to provide a definition of “armed group operating in the Central African Republic” and a definition of an “associated individual” of such a group. Regulations 21 to 28 of the CAR Regulations are amended in light of these changes.

A full impact assessment has not been produced for these Regulations as no, or no significant, impact on the private, voluntary or public sector is foreseen. An impact assessment was, however, produced for the Sanctions and Anti-Money Laundering Act 2018 and can be found at:

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/653271/Sanctions_and_Anti-Money_Laundering_Bill_Impact_Assessment_18102017.pdf.

The Explanatory Note confirms the legal basis for these Regulations under the Sanctions and Anti-Money Laundering Act 2018, stating their purpose is to amend the prior 2020 CAR Sanctions Regulations.

The amendments specifically reflect updates mandated by UN Security Council Resolutions 2745 (2024) and 2789 (2025).

It details that these changes involve updating Regulation 4 to reflect the arms embargo scope change concerning armed groups, defining these groups and associated individuals in Regulation 20, and updating Regulations 21 through 28 accordingly.

The note concludes that a full impact assessment was not produced because no significant impact on the private, voluntary, or public sectors is anticipated.

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