Mr. Sanctions

Category: OTSI (UK)

  • April 9, 2026: OTSI adds sanctioned goods to its licensing responsibilities

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    Expanding OTSI’s Licensing Remit

    Today, the Office of Trade Sanctions Implementation (OTSI) has published an update on OTSI’s expanding licensing remit. In addition to its existing remit for standalone services, from Monday 27 April, OTSI will become responsible for licensing sanctioned goods (and associated ancillary services) for export. This will exclude goods and associated ancillary services which are also subject to export controls. The update explains the changes and what this means for exporters when applying for an export licence for sanctioned destinations via SPIRE.

    Here’s the blog post:

    Expanding OTSI’s Licensing Remit 

    The Office of Trade Sanctions Implementation (OTSI) will soon be expanding its licensing role. From Monday 27 April, OTSI will become responsible for licensing sanctioned goods (and associated ancillary services) for export to sanctioned destinations. This builds on OTSI’s existing responsibilities for licensing sanctioned standalone services, such as professional business services. 

    Licensing goods and ancillary services which are subject to both strategic export controls and sanctions, as well as goods and ancillary services subject to export controls only, remains the responsibility of the Export Control Joint Unit (ECJU). 

    We will publish further information and updated guidance on export sanctions licensing ahead of Monday 27 April. We will also update statutory guidance to set out which licensing body has responsibility for specific prohibitions.

    What does this mean for you? 

    The application process for an export sanctions licence will not change. From 27 April, you should continue to submit applications to export all sanctioned goods to sanctioned destinations through DBT’s SPIRE service.  

    For now, OTSI will process licence applications for the export of sanctioned goods and associated ancillary services controls via SPIRE. OTSI will be responsible for incoming applications from 27 April onwards. 

    If your application includes goods and ancillary services subject to both sanctions and strategic export controls, it will be assessed by ECJU on SPIRE, as now.  

    Where applicable, OTSI will issue a Standard Individual Export Licence (SIEL) via SPIRE. This will ensure the licences OTSI issues for the movement of goods can be provided to HM Revenue & Customs (HMRC) and Border Force immediately, to minimise any disruption to business. 

    Exporters seeking a sanctions licence to provide standalone services should continue to use the dedicated OTSI online portal. 

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  • March 12, 2026: UK Government improves its sanctions guidance

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    Improved statutory guidance for sanctions regimes 

    To make guidance on UK sanctions regimes clearer and easier to navigate, we’ve introduced a series of improvements to structure and wording of the statutory guidance. 

    You do not need to take any action. These changes make the sanctions guidance easier to read and use, and do not reflect changes to the meaning of the text or scope of the regulations.
      

    Summary of changes to statutory guidance, by section: 

    1. Prohibitions and requirements: Minor changes to text throughout. Wording under ‘Director disqualification’ and ‘Information and record keeping’ is updated, and an introductory section added. 
    2. Enforcement: Deletion of content that duplicates departmental enforcement guidance. This section will link out to departmental guides.
    3. Licences and exceptions:   

    3.1 Exceptions: Added introductory definition of exceptions. Each exception now has a header, and links to additional departmental guidance where helpful. New ‘lookup’ guide for exceptions to the Belarus trade and transport sanctions.

    3.2-3.4 Licensing: Added introductory definition of licences. Restructured content on licensing considerations. New ‘lookup’ guide for considerations for trade licences under the Belarus sanctions.

    4. Further information: Simplified by linking to a single centralised place for departmental contacts on the sanctions hub page. 

    Statutory guidance for all regimes is collated here: Current UK sanctions regimes – GOV.UK 

    Older versions of statutory guidance and other GOV.UK pages can be accessed for reference via the National Archives Web Archive. 

    This improvement to sanctions guidance delivers on recommendation ii of the May 2025 cross-Whitehall review of sanctions. 

    The UK Sanctions List from FCDO lists which people, entities and ships are designated or specified under the Sanctions and Anti-Money Laundering Act 2018, and why.

    Find out more about UK Sanctions and how to contact us here: UK sanctions – GOV.UK

    This is a joint announcement from: 

    Foreign, Commonwealth & Development Office // Office of Financial Sanctions Implementation // Office of Trade Sanctions Implementation 

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  • March 10, 2026: UK government publishes new sanctions enforcement strategy

    Here’s a summary for non-expert practitioners of the strategy document published today under the auspices of FCDO (Foreign, Commonwealth & Development Office), the Department for Transport, HMRC (Her Majesty’s Revenue & Customs), NCA (National Crime Agency), OFSI (Office of Financial Sanctions Implementation), and OTSI (Office of Trade Sanctions Implementation):

    The “UK Government’s Strategic Approach to Sanctions Enforcement,” published in March 2026, marks a significant shift in the UK’s sanctions regime. For those with a basic grounding in the subject, the core message is that the government is moving from a phase of rapid policy creation (largely driven by the 2022 invasion of Ukraine) to a phase of aggressive, transparent, and coordinated enforcement.

    The document sets out a roadmap for how the UK will use civil and criminal powers to ensure sanctions are not just “on the books” but are actively enforced.

    1. The Strategic Shift: A “Unified Front”

    The most notable change is the emphasis on a cross-government approach. Enforcement is no longer siloed within the Treasury (OFSI). Instead, it is a coordinated effort across several key agencies:

    • OFSI (Office of Financial Sanctions Implementation): Leads civil enforcement for financial breaches and the Oil Price Cap.
    • OTSI (Office of Trade Sanctions Implementation): A newer body (launched in late 2024/early 2025) that handles civil enforcement for trade in services and goods moving outside the UK.
    • HMRC: Continues to handle trade sanctions at the border and strategic export controls.
    • National Crime Agency (NCA): Focuses on the most serious criminal evasions, particularly those involving “enablers” (lawyers, accountants) and organized crime.

    2. New Enforcement Tools and “Carrots” for Compliance

    The government has introduced a more sophisticated “toolkit” to encourage self-reporting and resolve cases faster. For a non-expert, the key takeaway is the new discount structure for penalties:

    • Early Account Scheme (EAS): Entities can get up to a 20% discount if they provide a full factual account of a breach very early in an investigation.
    • Settlement Scheme: A further 20% discount is available if a firm agrees to settle without a full formal investigation, similar to “plea deals” in other legal contexts.
    • Voluntary Disclosure: While the discount for serious cases has been adjusted to 30%, firms can combine these schemes. If a firm self-reports, provides an early account, and settles, the total penalty can be reduced by up to 70%.
    • Fixed Penalties: Minor reporting or licensing breaches now face “fast-track” fixed penalties of £5,000 or £10,000, intended to act as a “slap on the wrist” that avoids years of litigation.

    3. “The Stick”: Higher Penalties and Strict Liability

    While there are more ways to reduce a fine, the maximum “stick” has become much larger:

    • Doubled Penalties: The statutory maximum for financial sanctions breaches has doubled to the higher of £2 million or 100% of the breach value (up from £1m/50%).
    • Strict Liability: The government reiterated that for civil penalties, they do not need to prove you knew you were breaking the law (the “strict liability” standard). If a breach happened, you are liable, though “knowledge” is now considered an aggravating factor that will lead to a higher fine.

    4. Enforcement Principles

    The strategy outlines four “Guiding Principles” for how the government will act:

    1. Proportionality: Focus on the most serious and harmful breaches.
    2. Consistency: Ensuring similar breaches face similar consequences across different agencies (e.g., OFSI and OTSI).
    3. Transparency: Using “teachable moments.” The government intends to publish more details about enforcement actions so other businesses can learn from the mistakes of others.
    4. Due Process: Ensuring firms have the right to represent themselves before a final penalty is issued.

    5. Key Focus Areas for 2026

    • Ownership and Control: The government is providing more clarity on the “50% rule” and how to determine if a sanctioned person “controls” an entity even if they don’t own it.
    • Cryptoassets: There is a renewed focus on the use of crypto for sanctions evasion, treated with the same severity as traditional currency.
    • The “Enablers”: A specific warning to the professional services sector (legal, financial, and real estate) that facilitating “workarounds” will be a priority for criminal prosecution by the NCA.

    Summary for Businesses

    If you have a basic grounding in sanctions, this document tells you that “ignorance is no longer an excuse.” The government expects firms to have robust compliance systems and is signaling that while they are willing to be lenient with those who self-report and cooperate (via the new discount schemes), they will be significantly harsher on those who are caught through investigation or who display “reckless” behavior.

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