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.

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.

STATUTORY INSTRUMENTS

2026 No. 436 SANCTIONS

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, 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.

Citation, commencement and extent

  1. -(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.

Amendments to the Syria (Sanctions) (EU Exit) Regulations 2019

  1. -(1) The Syria (Sanctions) (EU Exit) Regulations 2019( 2 ) are amended in accordance with this regulation.

(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'.

(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).
  • (4) Omit regulations 42 to 46.

(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'.

(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).'.

(7) In regulation 58 (trade: exceptions from further provisions)-

  • (a) omit paragraph (3); and
  • (b) in paragraph (5), omit the definition of 'luxury goods'.

(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).'.

(9) In regulation 88(2) (exercise of maritime enforcement powers), omit sub-paragraphs (d) and (e).

(10) In Schedule 2 (definitions of goods subject to certain trade prohibitions), omit paragraphs 6 and 7.

20th April 2026

Foreign, Commonwealth and Development

Stephen Doughty Minister of State Office

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]

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