The Sanctions and Anti-Money Laundering Act 2018 (SAMLA) will enable sanctions to continue uninterrupted when the UK leaves the EU.
Licence applications in the event of no-deal
March 22, 2019
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Under the new framework, any existing financial sanctions licence issued by the Treasury will remain valid until:
the date they are replaced by a licence under the new regime
until the expiry date stated on the licence
if they are revoked.
In the event of a no-deal Brexit, the following will be the case if applying for a licence or an amendment to an existing licence:
Up to EU Exit
OFSI will receive applications and amendment requests as normal.
After EU Exit
If you apply for a new licence or an amendment to an existing licence and the regime is under the new SAMLA SI, you will have to apply for a new licence under the SAMLA regime. The process for applying for a new licence under a SAMLA regime will follow the same format as the current application process. Further guidance will be provided in due course
If you apply for a new licence or an amendment to an existing licence, and the regime comes under EU retained law (i.e. there is not a SAMLA regime in place yet), amendments and licence applications will continue as they do currently.