UK updates Central African Republic sanctions, Jan 2026
If you teach international relations or you’re learning how UN decisions turn into UK law, here’s a live example you can use in January. On 15 December 2025 the Government made the Central African Republic (Sanctions) (EU Exit) (Amendment) Regulations 2025, laid them before Parliament on 16 December, and set an in‑force date of 6 January 2026, as recorded on legislation.gov.uk. The update keeps the UK aligned with the UN’s sanctions on the Central African Republic.
What changed is both technical and practical. The amendment updates the UK’s references to the UN Security Council’s CAR resolutions-adding 2536 (2020), 2588 (2021), 2648 (2022), 2693 (2023), 2745 (2024) and 2789 (2025)-and refreshes Regulation 4 on “purposes” so that the UK points to the precise UN paragraphs now governing the regime. An older reference to Resolution 2127 is replaced, and the arms embargo obligations are confirmed as coming from paragraph 2 of Resolution 2745, read with paragraph 1 of Resolution 2789.
The legal definitions are brought into the text so readers aren’t guessing. An “armed group operating in the Central African Republic” means a group that is party to an armed conflict in the CAR and is not acting on the instructions of, or under the direction or control of, the CAR Government. An “associated individual” includes anyone who is a member of such a group, or who takes part in activities they know or reasonably suspect are the group’s activities or will help the group carry them out.
Because these definitions sit in Regulation 20, they steer the rest of the regime. From 6 January it is prohibited to export or supply military goods, make military goods or technology available, transfer military technology, or provide technical assistance, financial services, funds, or brokering services where the recipient is an armed group operating in the CAR or an associated individual. The same focus applies whether the act is direct or indirect, and whether it is done yourself or through someone acting on your behalf.
The offences include an important safeguard that doubles as a learning point about mens rea. A person commits an offence if they breach a prohibition, but it is a defence to show they did not know and had no reasonable cause to suspect that the recipient was an armed group operating in the CAR or that the person was an associated individual, or that the provision would enable or facilitate armed hostilities in the CAR. In short, you need evidence‑based checks; turning a blind eye won’t do.
One notable drafting shift is away from geography alone. Earlier wording in places referred to sending items to a place in the CAR. The amendment centres on the identity of the beneficiary: the ban bites when the recipient is an armed group or an associated individual, wherever the goods or assistance start their journey. That makes end‑use checks and beneficiary screening the essential control for anyone in scope.
Brokering and non‑UK arrangements are specifically covered. The rules catch situations where someone arranges for goods or technology to be made available in a third country for supply to an armed group or associated individual, or arranges transfers of technology or technical assistance abroad that ultimately benefit those recipients. This is there to stop the use of transit hubs to work around the embargo.
The “enabling armed hostilities” provision is spelled out more clearly. Providing technical assistance, armed personnel, financial services or funds, or brokering related to those things, to or for the benefit of an armed group or an associated individual is prohibited where it relates to operations in the CAR or would otherwise enable or facilitate fighting there. The words “directly or indirectly” matter; intermediaries do not insulate you from responsibility.
Who should pay attention now? Exporters of parts and software with military applications, logistics and insurance firms moving cargo through Central Africa, banks processing payments linked to higher‑risk actors, and humanitarian organisations or researchers operating near front lines all need clear internal guidance. The Government notes that no, or no significant, impact is expected, but in practice extra due diligence, documentation and staff training are often needed when definitions tighten and references update.
If you’re teaching this, map the pathway end‑to‑end. Start with the UN Security Council’s Resolutions 2745 (2024) and 2789 (2025). Move to the domestic tool-the Sanctions and Anti‑Money Laundering Act 2018-which lets ministers implement UN obligations. Then show this specific instrument, signed by Minister of State Stephen Doughty at the Foreign, Commonwealth and Development Office on 15 December 2025. Finish with the UK timeline: made 15 December 2025, laid 16 December 2025, in force 6 January 2026. That’s how global rules become rules you and I must follow.
What this means in practice: if your work could reach armed actors in the CAR, assume the embargo applies to goods, software, services and finance as well as weapons. Before acting, ask three questions-who will benefit, what exactly are you providing, and could it enable fighting in the CAR. If you cannot answer with confidence and evidence, pause and seek specialist advice. Source for all legal details: legislation.gov.uk and the UN Security Council resolutions named above.