The UK has laid Statutory Instrument 2025/1327, the Central African Republic (Sanctions) (EU Exit) (Amendment) Regulations 2025. Made on 15 December 2025, laid before Parliament on 16 December 2025 and in force from 6 January 2026, the measure amends the 2020 CAR Regulations under the Sanctions and Anti-Money Laundering Act 2018. The instrument was signed by the Foreign, Commonwealth and Development Office Minister of State, Stephen Doughty, according to legislation.gov.uk.
The amendments implement the UN Security Council’s 2024 decision on the CAR arms embargo and its 2025 renewal. Regulation 4 now frames UK sanctions purposes by reference to paragraph 2 of Resolution 2745 (2024), read with paragraph 1 of Resolution 2789 (2025), and inserts additional resolution references to keep the regime aligned with UN obligations.
Regulation 20 introduces clear definitions that recast the scope of the embargo. An armed group operating in the Central African Republic is a party to an armed conflict in the CAR that is not acting on the instructions of, or under the direction or control of, the CAR Government. An associated individual includes a member of such a group or a person who takes part in activities they know or reasonably suspect are the group’s activities or will help the group carry them out.
Across Regulations 21 to 25, the prohibitions on exporting, supplying or delivering military goods, making military goods or technology available, transferring military technology, and providing technical assistance are re‑cast so that the target is an armed group operating in the CAR or an associated individual. Earlier wording tied to goods being for use in the CAR or to persons connected with the CAR is replaced with an actor‑based test.
Regulation 26 updates prohibitions concerning financial services and funds connected to military goods and technology. Direct and indirect provision of such services or funds to armed groups or associated individuals, or arrangements intended to support their access to military goods, technology or related assistance, are prohibited. Parallel offences cover making goods or technology available and the transfer of technology in this context.
Regulation 27 confirms that non‑UK brokering is within scope where it involves making military goods or technology available in, or transferring it from, a third country for supply to an armed group operating in the CAR or an associated individual. This retains the extra‑territorial reach typical of UK brokering controls and closes off indirect routes through third countries.
Regulation 28, which addresses enabling or facilitating armed hostilities, has been redrafted to specify the kinds of support that are prohibited when provided to or for the benefit of an armed group or associated individual. The list expressly includes technical assistance, armed personnel, financial services or funds, and brokering services relating to arrangements in non‑UK countries to provide those forms of support. The prohibition applies where the provision relates to the recipient’s operations in the CAR or otherwise enables or facilitates hostilities there.
Updated offence and defence language appears throughout the amended provisions, including Regulations 23, 24, 25, 26 and 28. In each case it is a defence to show that the person did not know and had no reasonable cause to suspect that the recipient was an armed group operating in the CAR or that an individual was an associated individual. This sets a reasonableness standard that places weight on documented due diligence, end‑use checks and escalation procedures.
Regulation 6 widens the list of relevant UN references for the designation criteria, so that breaches of arms embargo measures under Resolutions 2507, 2536, 2588, 2648, 2693, 2745 and 2789 can be taken into account when assessing whether a person is involved. Additional interpretive references to UN resolutions are inserted into Regulation 2. These changes support alignment with the UN list and subsequent UK designation decisions under the 2020 Regulations.
The instrument applies across the United Kingdom and does not alter the underlying licensing framework of the 2020 Regulations. Government’s explanatory note indicates no significant impact is expected across sectors. For compliance teams, the immediate tasks are to update screening to the actor‑based test, refresh contract clauses and end‑use attestations, review brokering and finance controls that touch third countries, and ensure records demonstrate the no knowledge and no reasonable cause to suspect defence ahead of commencement on 6 January 2026.