To know more, read the full PDF report.

Overview of the Office of Trade Sanctions Implementation (OTSI)

The Office of Trade Sanctions Implementation (OTSI) is a new government body launched in October 2024 as part of the Department for Business and Trade. Its primary job is to make sure trade sanctions are followed properly. While HM Revenue & Customs (HMRC) handles criminal enforcement and goods crossing the UK border, OTSI focuses on “civil enforcement.” This means they handle fines and penalties for businesses that break the rules regarding:

• Providing services that are under sanction.
• Moving or acquiring sanctioned goods or technology outside the UK.
• Services related to moving these goods, such as insurance or shipping.

OTSI also helps businesses understand the rules to prevent mistakes before they happen.

Managing Permissions and Enforcing Rules

A major part of OTSI’s work involves granting special permissions, known as licences, that allow businesses to carry out trade that would otherwise be banned.

• Permissions (Licensing): In its first year, OTSI received 60 applications for these licences. Most were for professional or business services related to the sanctions on Russia. It takes about 82 working days on average to get a decision. So far, 12 licences have been granted (either fully or partially), while others were refused, withdrawn, or found to be unnecessary.
• Enforcing the Law: OTSI investigates when companies or individuals are suspected of breaking trade sanctions. They have received 146 reports of potential rule-breaking, largely from the financial services sector. While no monetary fines have been issued yet, several investigations are underway, and some cases have been passed to HMRC for criminal investigation.
• Whistleblower Protection: New laws were introduced in 2025 to protect employees who report sanctions violations to the government, ensuring they are safe from unfair treatment at work.

Working with Businesses and Partners

OTSI does not work in isolation. A significant amount of effort has gone into building relationships to make sanctions more effective.

• Supporting Business: The office has held over 200 meetings, workshops, and webinars to help UK businesses understand their obligations. They have also released simple guides to help companies spot “red flags” where someone might be trying to get around the rules.
• Global and Local Cooperation: OTSI works closely with international allies—such as the US, EU, and Japan—to ensure sanctions are coordinated globally. Within the UK, they collaborate with other agencies like the Foreign Office and the National Crime Agency to share intelligence and improve enforcement.

Looking Ahead

The report outlines several goals for the future as OTSI expands its role:

• More Help for Businesses: They plan to offer more targeted advice and expand their “roadshows” to reach businesses across the UK, not just in London.
• Taking on More Responsibilities: In early 2026, OTSI will take over the responsibility for licensing export sanctions (except for military-related “strategic” exports).
• Smarter Enforcement: The office plans to improve how it uses data and intelligence to proactively find and stop rule-breaking, rather than just waiting for reports to come in.