UK sanctions update 2026: prior obligations licensing changes explained

On 23 April 2026, the UK Government announced the introduction of the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 (“the Regulations”), due to come into effect on 13 May 2026.

The prior obligations licensing ground

Of particular interest are the changes made to the prior obligations licensing ground. This ground enables a designated individual to satisfy an obligation to a non-designated person where that obligation arose before that individual was designated. Previously, OFSI’s approach to this licensing ground was limited to permitting the satisfaction of the obligation only via the designated person’s own frozen funds or economic resources.

Key changes introduced in the Regulations to prior obligations

The amendment in these latest Regulations will widen the scope of the prior obligations licensing ground to allow the obligation to be discharged on behalf of the designated person by a third party – using that third party’s own funds or economic resources. This change provides new routes for businesses and individuals to be paid for the services they agreed to provide to the designated individual before that individual was designated. It is anticipated that the new amendment will enable a wider range of prior obligations to be licensed and satisfied, providing a more effective and proportionate approach for non-designated third parties.

How Gherson can assist

The Gherson team have years of experience advising on a wide range of compliance matters, including sanctions. We regularly advise clients on sanctions rules and regulations and can assist parties with their prior obligations matters, particularly with the upcoming changes to the UK autonomous regimes, with the introduction of the new Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026.

If you have any questions arising from this blog, please do not hesitate to contact us for advice, send us an e-mail or, alternatively, follow us on X, Facebook, Instagram or LinkedIn to stay-up-to-date.

The information in this blog is for general information purposes only and does not purport to be comprehensive or to provide legal advice. Whilst every effort is made to ensure the information and law is current as of the date of publication it should be stressed that, due to the passage of time, this does not necessarily reflect the present legal position. Gherson accepts no responsibility for loss which may arise from accessing or reliance on information contained in this blog. For formal advice on the current law please do not hesitate to contact Gherson. Legal advice is only provided pursuant to a written agreement, identified as such, and signed by the client and by or on behalf of Gherson.

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