The Syria (Sanctions) (EU Exit) (Amendment) Regulations 2026
The Syria (Sanctions) (EU Exit) (Amendment) Regulations 2026 primarily amend the 2019 Syria sanctions framework, which was established following the UK's exit from the EU, based on subsequent amendments made in light of the collapse of the former Bashar Al-Assad regime in December 2024.
These regulations revoke prohibitions on trade related to gold, precious metals, diamonds, and luxury goods, while making necessary technical corrections, such as re-inserting the definition of 'petroleum products' in Regulation 57 and updating terminology referring to the Syrian government.
Arguments For
Amends existing post-Brexit sanctions regulations to reflect new political realities in Syria following the fall of the Bashar Al-Assad regime in December 2024.
Revokes specific trade prohibitions on high-value items like gold, precious metals, diamonds, and luxury goods, potentially easing trade consistent with updated foreign policy objectives.
Corrects previous amendments (specifically S.I. 2025/507) by re-inserting the definition of 'petroleum products' where necessary to maintain existing exceptions regarding petroleum products in Regulation 57, ensuring operational clarity.
Streamlines the regulations by omitting definitions and subsections related to previously prohibited goods that are no longer subject to restriction.
Arguments Against
Implementing changes to established sanctions regimes can create short-term confusion for businesses and enforcement agencies regarding current compliance obligations.
The amendment involves correcting errors stemming from previous instruments (S.I. 2020/590 and S.I. 2025/507), suggesting ongoing instability or complexity in the UK's sanctions framework for Syria.
Removing prohibitions on 'luxury goods' and certain financial assets might be politically controversial, depending on the current UK assessment of the successor Syrian government or associated entities.
The technical nature of the corrections, involving substitutions of definitions and complex internal cross-references, necessitates careful review by legal and compliance departments.
This Statutory Instrument has been printed to correct errors in S.I. 2020/590 and S.I. 2025/507 and is being issued free of charge to all known recipients of those Statutory Instruments.
This specific version of the Statutory Instrument is being printed solely to correct mistakes found in two previous instruments, S.I. 2020/590 and S.I. 2025/507.
The instrument is distributed free of charge to everyone who initially received the flawed versions.
Regulations made by the Secretary of State, laid before Parliament under section 55(3) of the Sanctions and Anti-Money Laundering Act 2018 (c. 13), for approval by resolution of each House of Parliament within twenty-eight days beginning with the day on which the instrument was made, subject to extension for periods of dissolution, prorogation or adjournment of both Houses for more than four days.
The Secretary of State created these Regulations under the authority granted by the Sanctions and Anti-Money Laundering Act 2018.
The instrument was presented to Parliament and requires approval by a vote in both the House of Commons and the House of Lords within 28 days of its creation, unless Parliament is in a recess lasting longer than four days.
STATUTORY INSTRUMENTS
2026 No. 436 SANCTIONS
The Syria (Sanctions) (EU Exit) (Amendment) Regulations 2026
This section identifies the document as a Statutory Instrument, cataloguing it as number 436 of 2026 under the domain of Sanctions.
The formal title is 'The Syria (Sanctions) (EU Exit) (Amendment) Regulations 2026'.
Made - - - -
20th April 2026
Laid before Parliament
21st April 2026
Coming into force - -
22nd April 2026
The Secretary of State officially made these regulations on April 20th, 2026.
They were formally presented to Parliament the following day, April 21st, 2026, and they took legal effect on April 22nd, 2026.
The Secretary of State, considering that the condition in section 45(2) of the Sanctions and AntiMoney Laundering Act 2018( 1 ) is met, makes the following Regulations in exercise of the powers conferred by sections 1, 5, 15(2)(a), 45, 54(2) and 62(6) of, and paragraph 11(a)(iii) of Schedule 1 to, that Act.
The Secretary of State enacted these regulations, determining that the criteria outlined in section 45(2) of the Sanctions and Anti-Money Laundering Act 2018 are satisfied.
The authority to create these rules comes from various specific sections and schedules within that same Act.
Citation, commencement and extent
- -(1) These Regulations may be cited as the Syria (Sanctions) (EU Exit) (Amendment) Regulations 2026.
- (2) These Regulations come into force on 22nd April 2026.
- (3) These Regulations extend to England and Wales, Scotland and Northern Ireland.
The first substantive regulation addresses how the instrument is referred to, its effective date, and its geographic scope.
The citation is the full title specified.
The rules became effective on April 22nd, 2026, and they apply across all parts of the United Kingdom: England, Wales, Scotland, and Northern Ireland.
Amendments to the Syria (Sanctions) (EU Exit) Regulations 2019
- -(1) The Syria (Sanctions) (EU Exit) Regulations 2019( 2 ) are amended in accordance with this regulation.
This key section details the changes being made to the primary legislation governing Syria sanctions implemented after the EU withdrawal, specifically the Syria (Sanctions) (EU Exit) Regulations 2019.
(2) In regulation 25(1) (definitions relating to goods and technology prohibited under Part 5) omit the definitions of 'gold, precious metals or diamonds' and 'luxury goods'.
In Regulation 25(1), which defines items restricted under Part 5 (likely related to trade restrictions), the specific definitions for 'gold, precious metals or diamonds' and 'luxury goods' are completely removed.
(3) In regulation 27 (interpretation of other expressions used in Part 5)-
- (a) in paragraph (3)(a), in the appropriate place, insert-
''the Government of Syria' includes its public bodies, corporations or agencies, its armed forces or any person acting on its behalf or at its direction;';
- (b) in paragraph (5) for 'Chapters 2 and 4' substitute 'this Part';
- (c) omit paragraph (6).
Regulation 27, which handles the interpretation of terms in Part 5, receives several updates.
First, the definition of 'the Government of Syria' is expanded to explicitly include its public bodies, armed forces, and anyone acting under its instruction.
Second, references to 'Chapters 2 and 4' are updated to refer generally to 'this Part'.
Finally, paragraph (6) is removed entirely.
- (4) Omit regulations 42 to 46.
The entirety of regulations 42 through 46 within the principal instrument are deleted.
(5) In regulation 48 (provision of interception and monitoring services), in paragraphs (1) and (3) for 'the Governing Authority of Syria' in both places it occurs, substitute 'the Government of Syria'.
In Regulation 48, which covers services related to interception and monitoring, the phrase 'the Governing Authority of Syria' is officially substituted with 'the Government of Syria' in paragraphs (1) and (3) wherever it appears.
(6) In regulation 57 (exceptions relating to petroleum products)-
- (a) in paragraph (7)-
- (i) omit the definition of 'kerosene jet fuel';
- (ii) for the definition of 'petroleum products' substitute-
''petroleum products' means any thing which falls within the following commodity codes-
- (a) 2710;
- (b) 2712;
- (c) 2713;
- (d) 2714;
- (e) 2715 00 00;';
- (b) after paragraph (7) insert-
'(8) Paragraph 1 of Schedule 2 applies for the purposes of the definition of 'petroleum products' in paragraph (7).'.
Regulation 57, dealing with exceptions for petroleum products, is modified significantly.
The definition for 'kerosene jet fuel' is removed from paragraph (7).
The definition for 'petroleum products' is replaced, restricting it to goods corresponding to specific commodity codes (2710 through 2715 00 00).
Additionally, a new paragraph (8) is added, directing that paragraph 1 of Schedule 2 must be used when interpreting this new definition of 'petroleum products'.
(7) In regulation 58 (trade: exceptions from further provisions)-
- (a) omit paragraph (3); and
- (b) in paragraph (5), omit the definition of 'luxury goods'.
Regulation 58, which addresses exceptions to further trade provisions, has paragraph (3) removed.
Furthermore, the definition of 'luxury goods' within paragraph (5) is also omitted.
(8) For regulation 84(3B) (trade enforcement: application of CEMA), substitute-
'(3B) Paragraph (3A) applies to the suspected commission of an offence under regulation 48(3) (provision of interception and monitoring services).'.
Regulation 84(3B), concerning trade enforcement and the application of the Customs and Excise Management Act, is replaced entirely.
The new text specifies that sub-paragraph (3A) is applicable when there is a suspicion of committing an offense related to providing interception and monitoring services, an offense outlined in regulation 48(3).
(9) In regulation 88(2) (exercise of maritime enforcement powers), omit sub-paragraphs (d) and (e).
Sub-paragraphs (d) and (e) are removed from regulation 88(2), which deals with the powers to carry out maritime enforcement activities.
(10) In Schedule 2 (definitions of goods subject to certain trade prohibitions), omit paragraphs 6 and 7.
Schedule 2, which lists goods subject to specific trade prohibitions, has paragraphs 6 and 7 removed from its text.
20th April 2026
Foreign, Commonwealth and Development
Stephen Doughty Minister of State Office
The instrument was signed by Stephen Doughty, Minister of State in the Foreign, Commonwealth and Development Office, on April 20th, 2026.
EXPLANATORY NOTE
(This note is not part of the Regulations)
These Regulations amend the Syria (Sanctions) (EU Exit) Regulations 2019 (S.I. 2019/792) ('the original Regulations'). These amendments are further to amendments made by the Syria (Sanctions) (EU Exit) (Amendment) Regulations 2025 (S.I. 2025/507) ('the 2025 Regulations') following the fall of the former regime led by Bashar Al-Assad in Syria in December 2024. These Regulations revoke trade prohibitions in the original Regulations relating to gold, precious metals or diamonds and luxury goods. Other consequential amendments are made as a result of the revocation of these prohibitions.
In relation to regulation 57 of the original Regulations, these Regulations omit the definition of 'kerosene jet fuel' which is no longer required as a result of the 2025 Regulations. These Regulations also insert a definition of 'petroleum products' into regulation 57(7) of the original Regulations. This replicates the definition of 'petroleum products' which was previously contained in paragraph 4 of Schedule 2 to the original Regulations but which was repealed by the 2025 Regulations. This is a necessary correction to re-insert the definition in regulation 57 to the extent that it remains necessary in relation to the exception for petroleum products contained in that regulation.
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: [URL]
This note clarifies that the changes update the 2019 Syria sanctions, building upon amendments made in 2025 after Bashar Al-Assad's regime fell in December 2024.
The primary changes involve removing sanctions against gold, precious metals, diamonds, and luxury goods, with other conforming changes made due to these removals.
A key technical correction involves reinserting the definition of 'petroleum products' into Regulation 57, restoring a definition that was removed by the 2025 Regulations but remains necessary for the existing petroleum product exceptions.
The government states a full impact assessment was not necessary as no significant financial impact on the private, voluntary, or public sectors is expected from these specific amendments.
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