The UK has updated its Central African Republic sanctions regime to align with recent UN measures, with changes taking effect on 6 January 2026. The instrument, signed by FCDO Minister of State Stephen Doughty on 15 December and laid before Parliament on 16 December, moves the framework from a destination‑based test to a recipient‑based test. In plain terms: firms must now prove who ultimately receives goods, services or funds, not just where shipments are headed, according to the legislation.gov.uk text.

The shift follows the UN Security Council’s 2024 decision to lift the state‑level arms embargo on the CAR while maintaining a targeted embargo against armed groups and associated individuals. The Council then renewed those measures on 29 July 2025 through Resolution 2789, extending them to 31 July 2026. These are the obligations the UK is now baking into domestic law.

Two new definitions anchor the update. An “armed group operating in the Central African Republic” is any group party to an armed conflict in the CAR that is not acting on the CAR government’s instructions. An “associated individual” covers members of such groups and people who knowingly participate in activities of, or that support, those groups. This wording widens risk beyond named factions to include fixers, financiers and auxiliaries commonly encountered in mining, security and logistics chains.

Prohibitions already familiar to exporters are re‑cast around those recipients. It is now an offence to export or supply military goods, make military items or technology available, transfer military technology, or provide related technical assistance to an armed group or an associated individual-directly or indirectly. The same applies to financing and brokering tied to those activities, and to non‑UK brokering by UK persons. A new clarifier covers providing technical support, armed personnel, funds or brokering that would support operations in the CAR or otherwise enable hostilities there. The legislation preserves a defence where a person did not know and had no reasonable cause to suspect the recipient was an armed group or associated individual, but firms should expect that test to be evidence‑based.

For financial services, the practical effect is a higher bar for customer and transaction due diligence. Screening for named entities is not enough; banks, payment firms and insurers need to assess whether counterparties could be members of, directed by, or acting for armed groups-even where no sanctions listing exists. The UN’s targeted arms embargo against armed groups carries no exemptions, which limits the scope for UK licences to authorise activity where those recipients are in play.

Exporters and defence‑adjacent manufacturers should treat end‑use and end‑user checks as the decisive control. Documentation that previously focused on a consignee in Bangui or a regional hub must now establish that no armed group or associated individual will receive the goods, training, software or technical data. That includes intangible transfers such as remote support, sharing of CAD files, maintenance manuals and training modules delivered online or via field teams.

Brokers and insurers face extraterritorial exposure. The rules capture arranging deals in third countries that would place military goods or technology into the hands of armed groups or associated individuals, even if no UK‑origin items are involved. London‑based energy, mining and security brokers should review any “community security” payments, local guard contracting, or equipment packages bundled into project finance to make sure none benefit armed groups. The base 2020 CAR Regulations already apply to conduct in the UK and to UK persons worldwide; the amendment tightens who cannot be on the receiving end.

Compliance teams will want a paper trail that shows reasonable steps: enhanced counterparty mapping beyond company registries; questions about group affiliations and local security arrangements; checks on cash or in‑kind “protection” levies around mine sites or transport corridors; and adverse‑media sweeps in French and Sango as well as English. Where distributors or agents are used, contracts should prohibit sub‑contracting to local militias and require audit rights.

Context matters for risk scoring. The UN’s Resolution 2745 in 2024 removed the territorial embargo on the CAR government but kept the embargo on non‑state actors, and Resolution 2789 in 2025 rolled those restrictions forward for another year alongside travel bans and asset freezes on designated persons. If your transaction touches a conflict‑affected prefecture or a group known by an alias, treat it as high risk until proven otherwise.

What has not changed is the expectation of swift implementation. With commencement on 6 January 2026, firms have a short runway to update risk assessments, customer questionnaires, and screening logic so that they capture group membership and “associated” status-not just names on lists. For most UK SMEs there will be little direct trade with the CAR, but exposure can arrive indirectly through regional contractors, security providers, commodity intermediaries or project finance structures touching Central Africa.

Finally, remember that the policy move mirrors a global trend: sanctions regimes shifting from geography to behaviour. That makes compliance more investigative and less checklist‑driven. For UK traders, banks and brokers, the immediate task is simple if not easy-evidence the “no reasonable cause to suspect” standard with documented due diligence before the rules bite in early January.