Notice

NTI 2948: Libya import sanctions

Updated 30 April 2025

This notice provides an overview of the import prohibitions in force on certain goods imported into the UK, including Northern Ireland, that have originated or are consigned from Libya. It also sets out the licensing process for traders looking to import goods subject to prohibitions.

This notice should be read alongside the statutory guidance published by the Foreign, Commonwealth and Development Office (FCDO). This notice has no legal effect, and in case of conflict with the statutory guidance published by the FCDO, the statutory guidance will prevail.

Background

The Libya (Sanctions) (EU Exit) Regulations 2020 came into force on 1 January 2021 and have replaced, with substantially the same effect, relevant existing EU legislation, corresponding prohibitions in the Open General Import Licence (OGIL) and related UK regulations.

The Regulations impose financial, trade, transport and immigration sanctions for the purpose of giving effect to the United Kingdom’s obligations under United Nations Security Council Resolutions (UNSCR) including:

• 1970 (2011)
• 1973 (2011)
• 2009 (2011)
• 2095 (2013)
• 2174 (2014)
• 2213 (2015)
• 2362 (2017)
• 2441 (2018)
• 2146 (2014) (‘UNSCR 1970’, UNSCR 1973’, ‘UNSCR 2146’)
  • and the additional statutory purposes set out in the regulations

This sanctions regime is aimed at promoting respect for human rights in Libya, promoting the peace, stability and security of Libya, promoting the successful completion of Libya’s political transition, and preventing migrant smuggling and human trafficking in relation to Libya.

Import prohibitions

There is one import prohibition specified in the Libya Sanctions Regulations.

Regulation 24

Prohibits the import of arms and related material and internal repression goods which are consigned from or originate in Libya. This means that even if the immediate place the goods were shipped from was not Libya, the prohibition may still apply.

Exceptions

Part 8 of the regulations also sets out exceptions to some of the import prohibitions which apply within certain defined circumstances. An exception applies automatically and does not require you to obtain a licence issued in accordance with the Regulations. There is one exception specified in the Libya Sanctions Regulations.

Regulation 47

The prohibitions mentioned above do not apply if the act is one which a “responsible officer” (for example, a government or agency official) has determined would be in the interests of:

• national security, or
• the prevention or detection of serious crime in the United Kingdom or elsewhere

Trade sanction licences

A licence is a written authorisation that permits an otherwise prohibited activity. See guidance on how to apply for a trade sanctions licence for information on the types of trade sanctions licences available.

Please note, it is for the trader to carry out their own due diligence, determining any relevant controls or actions they may need to take, including obtaining the correct licence. If you are unclear about your obligations or responsibilities, you are advised to seek independent legal advice.

Import licences

DBT’s Import Controls and Sanctions Team is responsible for administering the licensing provisions on behalf of the Secretary of State for all trade sanctions licence applications from importers.

Where traders are looking to import prohibited goods, and where an exception does not apply, you will need to apply for an import licence. If you do not already have an account, you will need to create a GOV.UK One Login account. Once logged in, please submit an importer access request and, under ‘What are you importing and where are you importing it from’, please also state that you wish to apply for a Sanctions and Adhoc Licence, include your 12-digit EORI number and the relevant commodity codes associated with your import.

Once the importer access request has been approved, you will be able to submit your licence application. We will then consider each application on a case-by-case basis to determine whether granting a licence would be consistent with the stated purposes of the sanctions regime and any UN or other relevant international law obligations.

For certain prohibitions there are some specific activities that we consider likely to be consistent with the aims of the sanctions regime. These are set out below and in further detail in the statutory guidance. If you think that your proposed activity falls within one of these specific descriptions, you should make this clear and explain why you believe this to be the case in your application for a licence. The Secretary of State for Business and Trade is ultimately responsible for decisions to grant or refuse a trade sanctions licence in any individual case.

For further instructions, contact importsanctions@businessandtrade.gov.uk in the first instance, with details of your proposed import.

You should not assume that a licence will be granted or engage in any activities prohibited by trade sanctions until your licence has been granted. If you are unclear on any aspect of the regulations and in what cases a trade sanctions licence is required, we recommend that you seek independent legal advice in the first instance.

Licences granted will not permit activity in respect of Northern Ireland that is not consistent with EU sanctions regulations as they apply via the Windsor Framework^{[footnote 1]}. You will also have to comply with any other licensing requirements under UK import control legislation as applicable.

Enforcement of trade sanctions

The Customs and Excise Management Act 1979 (CEMA) makes it a criminal offence to contravene the trade sanctions. Some breaches of the import sanctions prohibitions are triable either way and carry a maximum sentence on indictment of 7 years’ imprisonment or a fine (or both). Under Regulation 72 of the Libya (Sanctions) (EU Exit) Regulations 2020, the maximum sentence has been modified to 10 years’ imprisonment. Any breach of the trade licensing provisions or information requirements in connection with general trade licences is also triable either way and carries a maximum sentence on indictment of 2 years’ imprisonment or a fine (or both).

HM Revenue and Customs (HMRC) is responsible for enforcing the licensing restrictions and investigating suspected offences.

If you discover that you have breached any of the trade prohibitions or licensing provisions, you should report the irregularity to HMRC (sometimes known as ‘voluntary disclosure’) as soon as possible.

Enquiries

For further information on import sanctions, contact importsanctions@businessandtrade.gov.uk.

For information on export controls:

• contact the Export Control Joint Unit (ECJU) on 020 7215 4594
• email exportcontrol.help@businessandtrade.gov.uk
• subscribe to the ECJU’s notices to exporters

For specific queries on export-related trade sanctions, contact tradesanctions@businessandtrade.gov.uk.

If your query is related to trade services sanctions, contact otsi@businessandtrade.gov.uk.

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This document is for information purposes only and has no force in law. Please note that where legal advice is required, importers should make their own arrangements.

1. ‘Windsor Framework’ has the same meaning as in Joint Declaration No.1/2023 of the EU and the United Kingdom in the Withdrawal Agreement Joint Committee of 24 March 2023. ↩