Background
In February 1992, the Organisation for Security and Co-operation in Europe (OSCE) requested that all participating states should introduce an embargo on ‘all deliveries of weapons and munitions to forces engaged in combat in the Nagorno-Karabakh area’. This request is still in effect.
2025 announcement
The UK Government issued a statement on 1 July 2025 that it has refined its 2 July 2014 interpretation of the OSCE arms embargo by:
- changing from ‘all’ the UK Military List to ‘Weapons, ammunition and munitions’
- removing ‘where this equipment could be used in the Nagorno-Karabakh region’ from the conditions
The UK’s embargo now applies to weapons, ammunition and munitions that might be used on the land border between Armenia and Azerbaijan by military, police, security forces and related government entities of either state.
‘Weapons, ammunition and munitions’ are those items specified in entries ML1, 2, 3 and 4 of the UK Military List of the Export Control Order 2008.
Supplies of such equipment to other end-users, such as humanitarian, peacekeeping, research or media organisations, will not be considered subject to the embargo, unless there is a risk of diversion to the land border for use by the military, police, security forces and related government entities of either state.
Controlled items
See the Consolidated list of strategic military and dual-use items that require export authorisation to check whether or not items are controlled.
All export and trade licence applications for Armenia and Azerbaijan as elsewhere will be assessed on a case-by-case basis against the UK Strategic Export Licensing Criteria and we will not issue a licence where to do so would be inconsistent with the Criteria.
Additionally, some goods which are not on the UK military list might also need an export licence. These are covered by the military end-use control.
Apply for an export licence through the online export licensing system managed by the Export Control Joint Unit (ECJU).
Transit control
Military items transiting the UK are still regarded as being exported when they leave the country and are therefore subject to control. Article 17 of the Export Control Order 2008 includes a transit and transhipment exception, meaning that in many situations a licence is not required. This exception does not apply to goods destined for Armenia or Azerbaijan, meaning that a licence is required to transit goods through the UK or to tranship them in the UK with a view to re-exportation to Armenia or Azerbaijan.
For further information on financial sanctions: contact the Office of Financial Sanctions Implementation [email protected]
For further information on export controls: contact the Export Control Joint Unit Helpline on 020 7215 4594 or email [email protected]
To receive updates about export controls and trade sanctions, subscribe to the Export Control Joint Unit’s Notices to Exporters
For further information on transport sanctions: contact the Department for Transport on [email protected]
For specific queries about the sanctions regime, email: [email protected]
