delete Authorisation to comply with Office of Foreign Assets Control licence
These 2022 Regulations amend the Protection of Trading Interests (Authorisation) Regulations 2021 by adding definitions for the Helms-Burton Act (Cuba sanctions) and laws relating to Iran, and authorizing Three Crowns (Services) LLP to comply with a specific US Office of Foreign Assets Control (OFAC) licence related to Iran. The existing Schedule was renumbered as Schedule 1, and a new Schedule 2 was added authorizing compliance with OFAC licence IA-2016-331681-3.
This regulation authorises UK companies to comply with US extraterritorial sanctions on Iran, effectively legitimising and enabling US jurisdictional overreach into British commerce. The underlying US sanctions regime is itself a distortion of free trade that harms ordinary Iranians and British businesses alike. Rather than selectively permitting one firm to comply with OFAC licences, Britain should cease recognising these extraterritorial sanctions entirely. This amendment perpetuates a regime where US law effectively overrides UK law for sanctioned activities, undermines UK sovereignty, and creates preferential treatment for one company while restricting trade with Iran for all others.