Emma RadmoreOFSI has published a list of FAQs for importers and exporters focussing on the application of financial sanctions. It notes the separate regimes and potentially the need for separate licences that may be required from OFSI in relation to financial sanctions and the Export Control Joint Unit for trade sanctions. It notes some key risks that importers and exporters could face, including that companies not from Iran are listed under the Iranian sanctions regime, and that it is important to know who and were goods or services are coming from and how they are being shipped. It also explains how sanctions may be relevant at various stages during the export chain.
The guidance also explains the licensing process for both OFSI and the ECJU, the interface with HMRC reporting and advises of the need to check for compliance with US sanctions for transactions in US dollars or involving US persons.
