Mr. Sanctions

Category: Guidance

  • September 10, 2026: OFSI updates travel expenses guidance

    Office of Financial Sanctions Implementation HM Treasury

    OFSI Updates Guidance on Permitted Travel Expenses for Sanctions Licence Applications

    OFSI has updated its guidance, ‘Permitted travel expenses for sanctions licence applications’, to clarify its expectations of applicants and align the guidance with wider OFSI guidance and current practice. 

    The update:

    • Clarifies that the guidance applies not only to travel undertaken by designated persons, but also to travel undertaken by legal representatives or other individuals where an OFSI licence is required to make the relevant payments;
    • Reflects current practice and expectations that applicants provide sufficient evidence at the outset and that OFSI may return an incomplete application for resubmission or refuse an application where adequate evidence is not provided;
    • Confirms that in exceptional circumstances, OFSI may license a flight in a class above that which is normally permitted;
    • Clarifies that where higher-cost travel or accommodation is not justified, OFSI may license a lower amount equivalent to permitted rates (subject to receiving sufficient evidence);
    • Confirms that each application will be assessed on its own merits; and
    • Removes outdated mileage rates and updates links to other relevant guidance.

    And the guidance:

    Guidance

    Permitted travel expenses for sanctions licence applications

    Updated 10 September 2026

    This guidance is produced by the Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, the authority for the implementation of financial sanctions in the UK. 

    This guidance sets out OFSI’s policy on licensing for travel and applies to travel and associated expenses for which an OFSI licence is sought. It is not limited to  travel undertaken by the designated person or their dependents and may include travel undertaken by a designated person’s legal or other representatives where an OFSI licence is required to make the relevant payments.

    This should be considered supplementary to, and not a replacement for, OFSI’s general guidance. Further sources of information that may prove helpful can be found at the end of this guidance.

    This guidance does not represent legal advice.

    If you are unsure about your obligations in a given case, you should consider seeking independent legal advice.

    1. Licensing travel expenses

    If you are applying for a licence from OFSI to release otherwise frozen funds for the purpose of travel and associated expenses, (for example, to allow you to attend legal meetings or court hearings), you will likely come across the term ‘reasonableness’. An associated expense may be incurred by attending legal meetings or court hearings for example, and when issuing a licence to enable the payment of such expenses, OFSI is legally obliged to ensure that those expenses are ‘reasonable’ as required under the various regime or sector specific regulations made under the Sanctions and Anti-Money Laundering Act (2018).

    Each application is reviewed on a case-by-case basis and based on the facts provided, which may not necessarily be covered in this guidance.

    Applicants may also apply for travel costs under another licensing purpose which does not carry a requirement for OFSI to conduct a reasonableness assessment. Nevertheless, they should provide a full explanation as to why a specific licensing ground applies to their case.

    This guidance should be considered best practice and OFSI would expect the same considerations to be demonstrated. This guidance is not intended to cover all eventualities.

    2. Applying for a licence

    Various regime or sector specific regulations made under the Sanctions and Anti Money Laundering Act set out the basis upon which HM Treasury may issue a licence. The specific regime regulations appear on the financial sanctions targets by regime on GOV.UK.

    It is important that applicants consult the relevant regulations before applying to OFSI.

    Each set of regulations will have their own licensing purposes, but commonly the regulations will include two licensing purposes which include a ‘reasonableness’ test. These are ‘legal services’ and ‘maintenance of funds and economic resources’.

    OFSI generally receives requests under these licensing purposes to enable the payment of:

    • Reasonable professional fees for the provision of legal services

    • Reasonable expenses associated with the provision of legal services

    • Reasonable fees arising from the routine holding or maintenance of frozen funds or economic resources

    • Reasonable service charges arising from the routine holding or maintenance of frozen funds or economic resources

    It may be the case that other licensing grounds could be relevant to an application for travel expenses and applicants should provide an explanation as to why a specific licensing purpose reasonably applies to their case.

    OFSI receives many licence applications where applicants have not provided sufficient evidence of reasonableness or with no evidence at all.

    OFSI requires a significant level of evidence when scrutinising the reasonableness threshold. This is because the various specific regime regulations made under the Sanctions and Anti Money Laundering Act gives HM Treasury the power to issue licences, also stipulates legal fees and maintenance of funds and economic resources should be ‘reasonable’.

    If OFSI does not receive the level of detail it needs, OFSI may deem the licence application incomplete and return it to the applicant for resubmission, or refuse the licence application.

    In addition, applicants are strongly encouraged to apply to OFSI no less than four weeks in advance of making any travel arrangements.

    Reasonableness may have different meanings in different contexts and applicants should note that just because a payment has been licensed in a previous case, does not necessarily mean that it will be licensed again. OFSI assesses each application on a case-by-case basis and applicants will be required to justify the proposed expenditure in each application.

    OFSI does not want to cause delays to the consideration and issuance of any licence, so this guidance is aimed at setting out what information OFSI requires when considering if an application for travel costs is ‘reasonable’.

    Before making any travel arrangements or applying to OFSI for a licence, you should consider the following four criteria:

    Step 1. Consider alternatives to travel

    As a first step in all cases, applicants should consider whether there are any practical alternatives to travelling in the first place, such as video, audio or web-based conferencing. They should explain why these alternative options are not possible in their particular case.

    Step 2. Consider efficiency and cost-effectiveness

    If travel is deemed to be the only option available, then consideration should be given to efficiency and cost-effectiveness (booking in advance, travelling off-peak, using timed trains, economy or standard class), safety and security.

    Step 3. Consider necessity

    OFSI would expect that only those individuals who absolutely must travel, do so. Support staff, such as paralegals, trainees and secretaries for example, should not be included unless deemed to be essential. In such cases, applicants should provide a clear explanation as to why these additional people are considered necessary and justifying the additional, proportionate cost.

    Step 4. Apply for a licence before travel

    Applicants should make an application for a licence to OFSI no less than 4 weeks in advance of travel and before making any concrete arrangements. Where an applicant is unable to apply for a licence 4 weeks in advance then explanation as to why should be provided.

    3. Travel types

    The rates shown in this section act as an indicator as to what OFSI would ordinarily deem to be reasonable. In exceptional cases, OFSI may issue a licence exceeding these rates. Applicants will need to provide a clear explanation of such additional costs being reasonable, including supporting evidence.

    Designated persons subject to certain regimes may also be subject to a travel ban. The applicant should ensure that anyone subject to a travel ban also has permission to travel and the necessary supporting documents.

    In the event of a licence being issued for a travel expense, any travel ban in place would still apply and is not negated by any licence that may be issued by OFSI. It is the applicant’s responsibility to ensure they are aware of any such restrictions.

    3.1 Air travel

    The cost of air travel is governed by the fare structure as set by airlines on various routes, as well as the duration of the flight and calendar dates. Prices often rise at popular times of the year, such as school breaks or national holidays, so OFSI would expect timings to be fully considered in line with the earlier pre-planning section.

    For flights up to 6 hours, OFSI expects applicants to use economy class wherever possible, even if this means that flights may be very early or late, or alternative dates need to be considered.

    For flights more than 6 hours, OFSI expects applicants to consider efficiency and cost effectiveness, safety and security when booking flights.

    The table below should be used as a guide.

    If there are exceptional circumstances where a flight in a class above what is permitted is needed, applicants should provide an explanation and supporting documentation.  

    Where exceptional circumstances have not been demonstrated and a flight in a class above what is permitted has been booked, OFSI will generally only license the cost equivalent of the fare of the permitted class of travel. In these circumstances, OFSI requires applicants to provide supporting evidence demonstrating the cost of the permitted fare. If this evidence is not provided, OFSI may refuse the entire amount.

    Duration of flights[footnote 1]Class of flight which will normally be permitted
    Under 6 hoursEconomy and equivalent
    Over 6 hoursEconomy, Premium Economy and equivalents

    3.2 Taxis

    When making a licence application for taxi costs, the applicant will need to demonstrate that public transport has been considered and explain why the need for a taxi is appropriate and cost-effective.

    Please note that carrying important documents will not generally in itself be considered an adequate justification. Many people can and do carry important documents, laptops etc on public transport.

    3.3 Rail

    When travelling by rail, OFSI expects applicants to travel standard class and generally at off-peak times. Moreover, OFSI expects that these rail tickets should be booked in advance, wherever possible, to take advantage of any discounts that may be available.

    If an alternative class is required, applicants must explain how such costs are reasonable, like a higher class of air travel.

    3.4 Hire Cars

    The use of self-drive hire cars may be considered where this is cost-effective. The applicant will need to demonstrate their consideration of public transport options and explain how the need for car hire is appropriate and cost-effective.

    3.5 Private vehicles and motor mileage allowance

    The use of a private vehicle to travel on official business may be considered where the mileage rate provides a cost-effective means of transport. Applicants will need to provide mileage and destination details in their application and explain why this is cost-effective. Expected rates for mileage can be found at the link at the end of this document.

    3.6 Hotels

    OFSI will generally expect hotel stays to be minimised. Overnight accommodation should only be used where this is essential, for example, for a court hearing of more than one day. Applicants are expected to book the lowest reasonable class of hotel available, for example 3* rather than 5* wherever it is available. If overnight accommodation is essential, each case will be considered on its own merits. The general guidance provided by HMRC, which can be accessed through the link at the end of this document, will be a good indicator of costs that will be considered reasonable. Typically, OFSI would not licence a 4* and above hotel unless there are genuinely exceptional needs (such as a medical need for a particular facility). As with higher levels of air travel or rail travel, the applicant will need to explain how such costs are reasonable.

    Where a 4* hotel or above is booked without demonstrating genuinely exceptional needs or the unavailability of suitable 3* accommodation, OFSI may instead license the cost equivalent of 3* accommodation. In these circumstances, OFSI requires applicants to provide supporting evidence demonstrating this cost. If this evidence is not provided, OFSI may alternatively license an amount capped at the costs outlined in the HMRC guidance.

    3.7 Meals

    Where meals are not included in the costs of the hotel or otherwise provided, it is possible to include these costs in the overall travel costs being applied for. The following table provides information on expected subsistence rates in the UK.

    Meal LimitLondon LimitUK elsewhere
    Breakfast£6.00£6.00
    Lunch£10.00£10.00
    Dinner£25.00£20.00

    Subsistence rates outside of the UK will depend on the location of travel and will be assessed on a case-by-case basis.

    4. Further support

    For further support with UK financial sanctions, you can:

    4.1 Further licensing information

    OFSI’s Introduction to Licensing Blog

    OFSI’s Blog on Reasonableness

    Reasonableness in licensing – updated approach

    HMRC Expenses Rate

    HMRC Travel — mileage and fuel rates and allowances

    1. In line with CAPA Centre for Aviation’s definition of long and short haul flights Aviation Industry Glossary CAPA ↩

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  • September 2, 2026: Finally – OFAC reminds you of the ARBP filing, issues new versions of Venezuela GLs, and amends a related FAQ

    Reminder to file the 2026 Annual Report of Blocked Property; Issuance of Amended Venezuela-related General Licenses and Frequently Asked Question

    09/02/2026

    Recent Actions Body

    On July 1, 2026, the Office of Foreign Assets Control (OFAC) issued a recent actions notice, reminding U.S. persons holding blocked property as of June 30, 2026, to file an Annual Report of Blocked Property (ARBP) no later than September 30, 2026. Failure to file the ARBP by September 30 may lead to an enforcement referral.

    For additional information, please review OFAC’s Guidance on Filing the 2026 Annual Report of Blocked Property.

    Additionally, OFAC is issuing Venezuela-related General License 51D, “Authorizing Certain Activities Involving Venezuelan-Origin Coal or Minerals, Including Gold;” Venezuela-related General License 54C, “Authorizing the Supply of Certain Items and Services for Coal or Minerals Operations in Venezuela;” and Venezuela-related General License 55A, “Authorizing Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela’s Coal or Minerals Sectors.”

    Lastly, OFAC has amended one Venezuela-related Frequently Asked Question, FAQ 1247.

    The guidance:

    arbp_guidance_2026Download

    GL 51D:

    venezuela_gl51dDownload

    GL 54C:

    venezuela_gl54cDownload

    GL 55A:

    venezuela_gl55aDownload

    and the FAQ:

    1247. Do non-U.S. persons face sanctions risk for engaging in transactions authorized by General Licenses (GL) 46D, 51D, and 52B? 

    No, provided that non-U.S. persons comply with certain conditions outlined in GLs 46D, 51D, and 52B as described below. Subject to certain conditions, GLs 46D, 51D, and 52B authorize established U.S. entities to engage in certain transactions involving Petróleos de Venezuela, S.A. (PdVSA), as well as certain transactions with the Government of Venezuela, including Carbones del Zulia S.A. (Carbozulia), PdVSA, or CVG Compania General de Mineria de Venezuela CA (Minerven) that are ordinarily incident and necessary to, among other activities, the exportation, sale, supply, storage, purchase, delivery, or transportation of Venezuelan-origin oil, petrochemical products, minerals (including gold), or coal. Generally, non-U.S. persons do not risk exposure to U.S. sanctions for engaging in transactions authorized under GLs 46D, 51D, and 52B — such as transacting with PdVSA or importing Venezuelan-origin oil, petrochemical products, minerals, or coal, into a third country — provided that:

    • The non-U.S. entity was organized under the laws of a third country on or before January 29, 2025;
    • Any monetary payment to a blocked person, excluding payments for local taxes, permits, or fees, is made into the Foreign Government Deposit Funds, as specified in Executive Order 14373 of January 9, 2026, or any other account as instructed by the U.S. Department of the Treasury;
    • The payment terms are commercially reasonable;
    • The payment terms do not involve debt swaps, and are not denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela, including the petro;
    • The transaction does not involve a person located in or organized under the laws of the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, or any entity that is owned or controlled, directly or indirectly, by or in a joint venture with such persons;
    • The transaction does not involve an entity located in or organized under the laws of Venezuela or the United States that is owned or controlled, directly or indirectly, by or in a joint venture with a person located in or organized under the laws of the People’s Republic of China;
    • The transaction does not involve a blocked vessel; and
    • With respect to GL 51D, the transaction does not involve the processing or refining of Venezuelan-origin coal or minerals, including gold, in the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, or the People’s Republic of China.

    These conditions are designed to ensure that transactions involving the Government of Venezuela, including Carbozulia, PdVSA, Minerven, or Venezuelan-origin oil, petrochemical products, minerals, or coal occur through legitimate and authorized channels, consistent with efforts to restore prosperity, safety, and security to Venezuela. Non-U.S. persons who continue to transact with PdVSA or Minerven, or import Venezuelan-origin oil, petrochemical products, minerals including gold, or coal, without complying with the above conditions risk being designated themselves, including for providing financial, material, or technological support to blocked persons, being responsible for or complicit in a transaction involving deceptive practices or corruption and the Government of Venezuela, or operating in the gold or oil sectors of the Venezuelan economy.

    Please note that GL 52B contains additional restrictions on engaging in certain transactions prohibited by other Venezuela-related Executive orders, such as transactions related to bonds and debt issued by PdVSA, as well as on the entry into a settlement agreement or the enforcement of any lien, judgment, or other order through execution, garnishment, or other judicial process purporting to transfer or otherwise alter or affect property or interests in property of any persons blocked pursuant to the Venezuela Sanctions Regulations.

    Please see FAQ 1226 for the definition of “Venezuelan-origin oil,” which includes petroleum products.

    Please see FAQ 1232 for what OFAC considers “commercially reasonable terms.”

    Please see FAQ 1239 for information on how to make authorized payments to the Foreign Government Deposit Funds, as specified in E.O. 14373.

    Date Updated: September 02, 2026

    Updated on Sep 02, 2026

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  • July 24, 2026: How to tell if you’re talking to OFSI (or not)

    Office of Financial Sanctions Implementation HM Treasury

    New guidance on verifying communications claiming to be from OFSI 

    OFSI has published new guidance on how to verify whether communications claiming to be from OFSI are genuine. 

    The guidance provides information to help individuals verify communications claiming to be from OFSI, including signs that a communication may not be genuine and sets out what to do if you are unsure. 

    The guidance:

    Check if an email or communication claiming to be from OFSI is genuine

    OFSI will never ask you to make a payment, transfer cryptocurrency, pay a fee to obtain a licence, or pay to release frozen funds. 

    1.  I’ve received a suspicious email or communication claiming to be from OFSI. What should I do? 

    If you receive a suspicious communication claiming to be from OFSI, HM Treasury or another government body: 

    • do not reply 
    • do not click any links or open attachments 
    • do not make any payments 
    • do not use the contact details they have provided 

    Instead, use the official contact details published on GOV.UK. If you’re unsure if a communication is genuine, contact OFSI directly at ofsi@hmtreasury.gov.ukimmediately. 

    2. How to check if an OFSI email or letter is genuine  

    Official OFSI emails are sent from: 

    Official UK government email addresses end in ‘gov.uk’. Always check the full email address carefully. 

    Scammers may use email addresses or display names that appear to come from a UK government department. 

    They may also use official-looking documents, branding, formatting or language to make communications appear genuine. A professional-looking email or letter does not mean it is authentic. 

    3. Does OFSI contact people by text message or WhatsApp? 

    No, OFSI will never contact you via: 

    • Text message  
    • WhatsApp 

    If you receive a message claiming to be from OFSI through these channels, you should treat it as suspicious.  

    4.  Signs an OFSI communication may be a scam 

    Be cautious if a communication claiming to be from OFSI: 

    • Asks you to pay a fee for an OFSI licence application. Applications for OFSI licences are made through the official GOV.UK website and there is no charge to apply for a licence   
    • Asks you to send or transfer money, cryptocurrency, or make a payment to unfreeze funds or release assets. OFSI does not require individuals to transfer money or cryptocurrency to obtain a licence, release frozen funds or assets, avoid enforcement action, or verify compliance with UK financial sanctions. Funds are frozen by relevant persons, such as banks, in accordance with UK sanctions legislation. Payment to OFSI, a bank or a third party will not unfreeze funds. 
    • Asks you to provide personal, banking or financial information. Genuine OFSI communications will not ask you to provide sensitive financial information or security credentials unexpectedly. If you are unsure whether a communication is genuine, contact OFSI directly using the contact details published on GOV.UK.  
    • Pressure you to make an immediate payment to avoid fines, penalties or other consequences. Communications that demand urgent payment or threaten enforcement action if you do not pay should be treated with caution. 

    5.  Report a scam or phishing email 

    If you believe you have received a scam or phishing email claiming to be from OFSI, you can report it to the National Cyber Security Centre.

    If you’ve been a victim of a scam, suffered financial loss or responded to a scam communication, report it to Report Fraud through their website or to Police Scotland by calling 101 if you live in Scotland.  

    You can report fraud to Report Fraud if you are in the UK, if the fraud occurred in the UK or if the fraud is related to the UK and the internet. Report Fraud also provides information on reporting fraud in a range of languages and guidance for people who may need support accessing its services. 

    If you live outside the UK, you can also report it to your local law enforcement agency or the relevant fraud reporting authority in your country.

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  • June 23, 2026：New OFSI–OFAC Joint Guidance: Comparative Overview of UK and U.S. Sanctions Regimes

    On Tuesday, OFSI and OFAC both published a joint guidance which compares the two sanctions regimes:

    ofac_ofsi_comp_06232026Download

    And OFAC published a story about the partnership between the regulators:

    Achieving our Objectives, Supporting our Stakeholders: OFAC-OFSI Enhanced Partnership Exchange 2026

    June 23, 2026

    Sanctions are among the most powerful tools available to the U.S. and UK governments in advancing our respective foreign policy and national security interests. In January 2026, as part of the continuing Enhanced Partnership, the HM Treasury’s Office of Financial Sanctions Implementation (OFSI) and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) met for the latest in-person exchange in London. 

    The week-long strategic dialogue focused on how we use our respective authorities to meet foreign policy and national security demands, such as tightening or lifting sanctions, adopting new technology, and highlighting enforcement efforts. The exchange reinforced our shared commitment to ensuring sanctions are administered in a way that is as effective and clear as possible to the public.

    Building on this cornerstone goal, we are publishing additional joint guidance, The U.S. and UK Economic Sanctions Authorities: A Comparative Overview. The guidance compares key aspects of U.S. and UK sanctions regimes, identifying similarities and differences on topics such as sanctions lists, licenses, as well as recordkeeping and reporting requirements. This new publication focuses on ensuring that those who are required to comply with our sanctions have a clear and strong understanding of how to do so. 

    SHARED OBJECTIVES, EVOLVING PRIORITIES

    Sanctions remain at the forefront of our respective governments’ response to geopolitical events in an increasingly complex world. While we continue to clarify and communicate existing rules, practices, and expectations, evolving priorities shape our work and often require new approaches, measures, or even new sanctions regimes.

    In response to dynamic demands, OFAC and OFSI continue to use a range of tools to ensure sanctions remain effective and aligned with shared objectives. For instance, OFAC and OFSI identified the following opportunities to work together to improve the efficacy of our respective sanctions regimes: 

    • evaluate our parallel mechanisms to enable us to rapidly increase sanctions pressure;
    • harness lessons learned from the novel restrictions developed as part of our coordinated response to Russia’s illegal invasion of Ukraine to apply to other scenarios;
    • identify typologies and economic impact of sanctions targets to more effectively disrupt concerning behavior, such as in relation to the shadow fleet;
    • review and enhance processes necessary to dismantle sanctions regimes in a structured way, such as in Syria; and
    • translate the lessons learned and insights from our global sanctions regimes, such as counternarcotics or illegal migration, to produce new tools and resources that can be applied across shared sanctions regimes.

    A coordinated approach to developing and deploying these measures remains essential to ensuring sanctions have the most impact across jurisdictions.

    NEW TOOLS, BETTER SYSTEMS

    Measuring the real-world impact of sanctions is critical to demonstrating effectiveness. During our recent exchange, OFAC and OFSI explored the methodologies and technological tools available to assess the disruptive effect of sanctions. Quantitative analysis is not only vital to understanding how to target malign actors more effectively, but also to assess where additional mitigation, such as licences or exceptions, are necessary. Investing in new tools that improve impact analysis is essential to OFAC and OFSI implementing sanctions more effectively. For our stakeholders, keeping pace with technological advancements allows us to more effectively utilise different data sources, whether it be stakeholder feedback, licence application information, or private sector-developed data to resolve emergent problems affecting global industries.

    Similarly, we are always conscious of the impact sanctions can have on our stakeholders and their compliance teams. To reduce the burden of sanctions while meeting increased demands, we continue to modernise systems for applying for licences, disclosing violations, submitting reports, or seeking guidance. This includes sharing our experiences using artificial intelligence to support our functions going forward. We expect the use of emerging technologies to automate routine tasks or support information analysis to ultimately lead to improved decision-making, provide clearer guidance for industry seeking support, and deliver improved public service to our stakeholders.  

    INTO THE FUTURE

    As our Enhanced Partnership enters its fifth year, much has changed, but our core mission remains the same. Sanctions should deliver maximum impact, minimise unintended consequences, and be easily understood and implemented. This most recent exchange builds on our strong foundations: regular engagement, information-sharing facilitated through the OFAC-OFSI Memorandum of Understanding, and joint industry engagements throughout the year. As the two largest implementing sanctions authorities, close contact on pressing matters impacting both of our jurisdictions remains crucial. We look forward to our next exchange this autumn in Washington DC.

    Giles Thomson, Director Economic Crime & Sanctions, The Office of Financial Sanctions Implementation, HM Treasury

    Bradley Smith, Director, Office of Foreign Assets Control, U.S. Department of the Treasury

    and OFSI published the above on its blog.

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  • May 20, 2026: ECJU updates military end-use controls guidance

    Export Control & Sanctions

    Military end-use controls

    The guidance on the UK’s military end-use controls has been updated to provide more detail on the scope and application of the enhanced control, which was extended in 2022 to cover a wider range of exports to destinations subject to UK arms embargoes.

    Building on the extensive exporter engagement ECJU has undertaken in recent months, this guidance now includes detail on types of exports that have been made subject to the enhanced military end-use control since 2022, updated case studies to help outline indicate whether the control would likely be applicable in different circumstances, and further considerations for businesses and research organisations. 

    These updates are intended to help exporters better understand which items are commonly controlled due to end-use concerns and to anticipate and better meet potential compliance obligations.

    ECJU’s website can be found on GOV.UK

    and here’s that guidance page (HTML only, sorry!):

    Guidance

    Military end-use controls

    When military end-use export controls apply and to which destinations.From:Export Control Joint Unit and Department for Business and TradePublished19 May 2022Last updated19 May 2026 — See all updatesGet emails about this page

    Disclaimer

    This guidance explains the operation of the military end-use controls set out in export control legislation. It does not constitute legal advice. If you are unsure about your obligations in any given case, you should consider taking independent legal advice.

    Military end-use controls

    The purpose of end-use controls is to allow export controls to be imposed, on a case-by-case basis, to goods, software and technology (referred to as ‘items’) which are not specified in the UK Strategic Export Control Lists. In practice, this means that even if the items which you intend to export do not usually require an export licence, you might still require one.

    Circumstance 1: Where the purchasing country or country as of destination is an embargoed destination and the exporter has been informed in writing by the Export Control Joint Unit (ECJU), or is aware, that otherwise non-controlled items are or may be intended:

    • for incorporation into military items listed in Schedule 2 (the UK military list) to the Export Control Order 2008
    • for the use of production, test or analytical equipment and components therefor, for the development, production or maintenance of military items listed in Schedule 2 (the UK military list)
    • for use in any unfinished products in a plant for the production of military items listed in Schedule 2 (the UK military list)

    Circumstance 2: Where the exporter has been informed, or is aware, that otherwise non-controlled items are or may be intended for use as parts or components of military items listed in Schedule 2 (the UK military list) to the Export Control Order 2008, when those military items were originally exported without authorisation or in violation of an authorisation granted by the Secretary of State.

    Circumstance 3: Where the exporter has been informed that otherwise non-controlled items are or may be intended for use by a ‘relevant entity’, which means:

    • any military forces, para-military forces, police forces, security services or government intelligence organisations of an embargoed destination
    • any person or entity involved in the procurement, research, development, production or use of items on behalf of these entities

    Circumstance 3 is commonly referred to as the ‘enhanced military end-use control’.

    The enhanced military end-use control does not apply to:

    • the export of medical goods, including medicines and medical devices for the benefit of the civilian population of a country
    • the export of consumer goods generally available to the public
    • the transfer of software or technology generally available to the public

    The enhanced military end-use control will also only be invoked, and a licence application refused, where it is assessed that the export would be capable of having a ‘relevant consequence’, within the meaning given to that term in the Schedule to the Export Control Act 2002.

    Such consequences include, in summary:

    • a threat to the UK’s national security
    • having an adverse effect on peace, security or stability
    • an act threatening international peace and security
    • an act contravening the international law of armed conflict
    • an act of internal repression
    • an act that breaches human rights
    • an act of carrying out (or of acts which facilitate) acts of terrorism or serious crime

    End-use controls applicable to Weapons of Mass Destruction

    Please note end-use controls also apply to weapons of mass destruction (WMD) related items and technical assistance. WMD end-use controls can be triggered in different ways to the military end-use control. You have an obligation under the export control legislation to notify ECJU if you are aware, have been informed by government, or suspect that your items are, or may be used for, WMD purposes.

    Typical items which could be in scope

    The enhanced military end-use control is not limited to specific technologies, capabilities or sectors, and can be used to control exports of any goods, software and technology as long as their end use could have a ‘relevant consequence’.

    However, the most common types of items made subject to the enhanced military end-use control include (but are not limited to):

    • aerospace and marine (including submersible) vehicle parts
    • biotechnology, including engineering biology or synthetic biology
    • materials analysis equipment
    • quantum computing technology, including enabling technologies for quantum programmes (such as imaging cameras and cryogenic equipment)
    • semiconductor design and manufacturing equipment
    • telecommunications or advanced connectivity technologies

    Note: This list is an indicative list based on licensing data since 2022 but is not exhaustive and may change over time.

    Embargoed destinations

    For the purposes of the military end-use controls, an ‘embargoed destination’ means a destination to which one or both of the following applies:

    • it is subject to an arms embargo imposed by the United Nations Security Council or the Organisation for Security and Cooperation in Europe (OSCE)
    • it is listed in Parts 1 or 2 of Schedule 4 to the Export Control Order 2008

    As of May 2026, the embargoed destinations are:

    • Belarus
    • Central African Republic
    • China (including Hong Kong and Macao)
    • Democratic Republic of the Congo
    • Democratic People’s Republic of Korea
    • Haiti
    • Iran
    • Iraq
    • Lebanon
    • Libya
    • Myanmar (Burma)
    • Russia
    • Somalia
    • South Sudan
    • Sudan
    • Venezuela
    • Zimbabwe

    What you must do when you are informed of a licence requirement

    You will be ‘informed’ that an export requires a licence under the military end-use control in writing. That letter will also set out the applicable legislation that makes the export licensable.

    A decision to make the export licensable and subject to the controls will be based on an assessment of both the specific items and specific end-user.

    The most common scenarios in which you may be informed an export licence is required are:

    • having submitted an export licence application to ECJU, before you receive a final decision, you may receive an electronic letter via the licensing system advising you that a licence is required – this means that even if you withdraw the application, a licence is still required if you wish to later export the same items to the same end-user
    • having presented goods for export, HMRC or Border Force detain the shipment for checks – if the detaining agency seek advice from ECJU, and we have concerns about the goods being used in an embargoed destination, you will receive a letter advising that an export licence is required, along with guidance on how to apply

    Once you are informed that an export requires a licence, you must then apply for an export licence to proceed with that export. It is a criminal offence to attempt to export items without a licence if you have been informed of the need for a licence by ECJU.

    End-User Advisory Service

    The End-User Advisory Service (EUAS) on Spire enables exporters to seek advice on whether exports to named overseas entities could require a licence because of the WMD or military end-use concerns. This focuses on the end-user and does not consider the types of items being exported and for what purpose.

    This advice is ‘non-statutory’ which means it does not constitute advice on how to follow the law and is no substitute for seeking your own independent legal advice. However, we recognise it is a helpful service to understand how export control rules might apply to complement exporters’ own due diligence.

    For the purposes of military end – use controls, any advice given through EUAS should be treated as a recommendation. It is not the same as being informed that the controls apply and a licence is therefore required for export. As set out previously, if that is the case you will be clearly informed by ECJU separately. Nonetheless, advice from EUAS may be relevant as to whether you are aware the military end use controls might apply.

    Apply for an export licence

    Apply for a standard individual export licence (SIEL).

    What you must do when you are aware of certain military end-uses 

    If you are aware that your items are or may be intended for one or more of the end-uses specified in circumstances 1 or 2, you must contact ECJU who will advise on whether an export licence is required.

    Additional due diligence and compliance guidance

    It is the responsibility of the exporter to fully determine the extent of their specific risk exposure to military end-uses, including risk of diversion, and to develop an appropriate set of safeguards tailored to the organisation’s particular circumstances.

    Staying up to date

    It is therefore important to stay up to date with changes to the UK’s export controls, and to consider how any amendments affect your organisation’s compliance obligations. ECJU regularly provides these updates via notices to exporters. Visit the collection page to see previous notices and to sign up to receive the e-mail alerts.

    Assessing end-users and risks of diversion

    While there is no one size fits all approach, it is also important to consider risks of diversion and whether the ultimate end-user may be – or may be working on behalf of – the military, police or security forces of an embargoed destination before making arrangements for an export or transfer.

    As well as using the EUAS, there are several steps your organisation can take when undertaking a risk assessment. This includes identifying potential red flag indicators of export controls evasion from open-source reporting and implementing an enhanced due diligence model to screen customers and business partners. In general, these practices could also be used to support subsequent licence applications. See guidance on compliance best practice and enhanced due diligence procedures for sanctions and export controls.

    Compliance Code of Practice

    The Compliance Code of Practice includes further guidance and advice on managing risks and ensuring compliance with export controls.

    Licensing process

    We assess all licence applications on a case-by-case basis against the Strategic Export Licensing Criteria. The Criteria provide a thorough risk assessment framework. We will not grant a licence when it is inconsistent with the criteria. Applications for countries subject to sanctions or embargoes are also considered against trade sanctions, arms embargoes, and other trade restrictions.

    In reaching a decision on an application, the Department for Business and Trade receives advice from several departments, including the Ministry of Defence and the Foreign, Commonwealth and Development Office. Processing licences for sanctioned, embargoed or highly sensitive destinations is likely to take significantly longer than the standard 20 working day target.

    See further information on the process and requirements for applying for a Standard Individual Export Licence.

    Example scenarios where an export licence may be required

    A. Exporting components for the repair or maintenance of military equipment to an embargoed destination:

    The military end-use control applies to exports of non-listed dual-use items where the items are for incorporation of military items (listed in Schedule 2 of the Export Control Order) or for the development, production or maintenance of military items in an embargoed destination. These apply to any exporter whether they are a business or an academic institution, and whether the export consists of a physical export or a transfer of technology (information).

    Example

    Exporter A is approached to supply commercial spare parts and equipment to an embargoed destination in order to undertake repair of a military aircraft. Exporter A is aware that the items will be used for the repair of military equipment listed in the military list in an embargoed destination. Exporter A therefore has an obligation to contact the ECJU who will advise whether an export licence is required.

    B. Exchanging research with a potential military application (upon being informed that a licence is required):

    The military end-use control may apply to transfers of technology (information) even if the technology is not explicitly intended for a military programme. If your role in a collaborative research project involves sharing technology with organisations (such as universities) in embargoed destinations and those organisations also work on programmes which may have an end-use concern, the military end-use control may apply.

    In this context, universities and research organisations should identify the risks that certain technologies pose to national security or human rights, as they may have applications in programmes of military concern, as well as civilian applications.

    Example

    Academic A works for a UK university and is collaborating on research with Academic B who works in an embargoed destination. Academic A exchanges (imports and exports) technology as part of their work.

    The research is intended to underpin development of civil vehicle technologies for the consumer market. However, Academic B is also working on projects exploring military applications for emerging civil vehicle technologies and the technology being exchanged could be applied to military programmes.

    The military end-use control would apply if Academic A has been informed that a UK export licence is required if it is assessed that the export of technology, in whole or in part, may be used to develop military capabilities of an embargoed destination.

    C. Exporting equipment to a large organisation that undertakes many areas of work (upon being informed that a licence is required)

    The military end-use control may apply to exports of equipment even if the intended end-use appears benign. If you are exporting equipment to an organisation that undertakes many different projects, such as a research organisation, and that organisation is supporting a programme of concern operated by the government or armed forces in an embargoed destination, then there may be a risk that the equipment may be used for purposes other than what is stated.

    Example

    Company A is exporting analytical equipment to a laboratory in a university in an embargoed destination. The laboratory declare that the equipment will be used by their project team to analyse new materials without a particular application, but the university is state-owned and equipment used by the laboratory is also available for use by other teams who undertake research and development (R&D) on behalf of the military.

    The military end-use control would apply if Company A has been informed that a UK export licence is required if it is assessed that the equipment might be used by teams working on military R&D programmes.

    D. Exporting items to a non-embargoed destination which could be diverted for use by an entity of concern in an embargoed destination

    The military end-use control may apply to exports even if the exported items are intended for use in a non-embargoed destination. If you are exporting items, even on a temporary basis, that are at risk of being diverted and used by a ‘relevant entity’ (for example the military) of an embargoed destination, there may be a risk that the equipment may be used for hostile purposes within scope of the ‘relevant consequences’ in the Export Control Act 2002. It is important that your due diligence processes consider all potential end-uses and end-users, including the risk of diversion to an embargoed destination.

    Example

    Company A is exporting underwater survey equipment to a distributor based in a shipyard in a non-embargoed third country. The distributor has a trading partnership with the navy of an embargoed destination, and could install Company A’s survey equipment on board a vessel operated by the navy. The military end-use control would apply where Company A was informed that a UK export licence was required because it is assessed that the vessel is undertaking operations that are a threat to national security of the UK or allies because of its connection with an embargoed destination.

    Further information

    What to do if you are aware that the items are intended for a military end-use in an embargoed destination

    If you are ‘aware’ that your items are or may be intended for one or more of the end-uses specified in circumstances 1 or 2, you must contact ECJU who will advise whether an export licence is required.

    If you are aware (but have not yet been ‘informed’) that the items are or may be intended for use by a ‘relevant entity’ (as described in circumstance 3‘enhanced military end-use control’), you should engage with the ECJU’s end-user advisory service and consider applying for a licence. As part of this process ECJU will determine whether a licence is required for the export and will inform you of this requirement.

    Typical types of end-users or end-uses to look out for

    The military end-use control is not limited to specific technologies, capabilities or programme sectors.

    The application of the control includes equipment with end-uses in many areas and the list of sectors is indicative of these cases.

    The control applies to the 17 embargoed destinations, which since 2022 include China (including Hong Kong and Macao). More specifically, your organisation should consider where your otherwise non-controlled items are or may be intended for use by a “relevant entity”, which means: * any military forces, para-military forces, police forces, security services or government intelligence organisations of an embargoed destination * any person or entity involved in the procurement, research, development, production or use of items on behalf of these entities.

    Considerations to minimise delays in an export licence application to make sure the process is an efficient as possible

    To minimise delays on export licence applications and ensure the most efficient process, you must provide comprehensive and accurate documentation, specifically focusing on clearly defining the items (technical specifications, model numbers, intended design use), as well as the end-user and end-use. In short, providing as much information as you have on your goods, customer and their intended use and the supply chain can help our advisers.

    Incomplete, inconsistent, or incorrect applications are a very common reason for delays, often resulting in requests for more information.

    Considerations for how to manage customer expectations when waiting for a licensing application outcome

    The government seeks to run a responsible export system, that enables UK growth whilst protecting national and global security. ECJU is very mindful of the commercial pressures on businesses, and the need to process licence applications with minimum delay. We strive to meet the public targets to conclude 70% of standard individual export licence applications within 20 working days and 99% within 60 working days.

    Some destinations remain more challenging to assess and therefore take longer, particularly where geopolitical situations are complex. Licence applications under military end-use controls can sometimes take longer to assess than exports caught by the control list.

    In general, we would also encourage exporters to review ECJU’s past processing performance in the licensing statistics we publish on a quarterly basis to help manage customer expectations.

    As with all licence applications, ensuring that you submit accurate and complete applications will help avoid delays. Making amendments to live applications can substantially impact the time it takes ECJU to assess it.  See more information about how to apply for a licence here: Apply to export controlled goods.

    Interaction with military end-use controls for universities when hosting visiting researchers or PhD students from embargoed destinations

    First, consider how other national security risks and regulations apply. The Research Collaboration Advice Team (RCAT) – which is part of the Department for Science, Innovation and Technology, provide advice to research institutions on the national security risks linked to international research.

    Generally, export controls do not apply to activity conducted wholly within the UK, except in specific cases where the WMD end-use control might apply.

    However, controls – including military end-use controls – could apply to any material the researchers or students send overseas from the UK (including via email and other forms of intangible transfer), or which they take home at the end of their stay.

    See guidance on how export controls can apply to the academic research from the UK.

    Contact ECJU

    General queries about strategic export licensing

    Export Control Joint Unit
    Department for Business and Trade
    Old Admiralty Building
    Admiralty Place
    London
    SW1A 2DY

    Email exportcontrol.help@businessandtrade.gov.uk

    Telephone 020 7215 4594

    Published 19 May 2022

    Last updated 19 May 2026

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  • Burning Question: What’s in OFSI’s Financial sanctions guidance for High Value Dealers & Art Market Participants?

    Here is the complete summary:

    What Is This Document?

    This guidance is produced by the Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, the authority for the implementation of financial sanctions in the UK. It provides financial sanctions guidance for entities and individuals that operate in the sale or trade of high value goods, especially those trading internationally with regions that may be subject to UK financial sanctions restrictions.

    In short: if your business buys, sells, stores, insures, or transports high-value goods — art, luxury cars, precious metals, jewellery, fine wine — this document sets out your legal obligations under UK financial sanctions law.

    Who Does This Apply To?

    High Value Dealers (HVDs)

    A “high value dealer” is defined as a firm or sole trader that by way of business trades in goods (including an auctioneer dealing in goods), when the trader makes or receives, in respect of any transaction, a payment or payments in cash of at least £10,000 in total, whether the transaction is executed in a single operation or in several operations which appear to be linked. This refers to physical cash only and does not include bank transfers or digital payments.

    Art Market Participants (AMPs)

    An art market participant is defined as a firm or sole practitioner who is registered or required to register with HMRC as an art market participant under the Money Laundering Regulations. Their obligations apply when they trade in or act as an intermediary in art sales of £10,000 or more, or store works of art worth £10,000 or more for a single person.

    Both categories were added to the list of “relevant firms” subject to financial sanctions reporting requirements from 14 May 2025.

    Why Does This Sector Get Special Attention?

    The UK is a major international hub for the trade of high value goods, including art, antiques, luxury cars, precious metals and gemstones, and for investment in wines and whiskies. In 2023, global art sales were USD $65 billion and the UK had the third largest share at USD $11.05 billion, accounting for 17% of the world market.

    This scale, combined with the sector’s characteristics — high-value, portable, often privately traded — makes it attractive to sanctioned individuals seeking to move or hide wealth.

    How Sanctioned Persons Try to Exploit This Sector

    The guidance identifies several red flags to be aware of:

    Shell companies and intermediaries. Intermediaries and shell companies are often used to source, buy, or sell high value goods, and any associated payments. Such anonymity and obfuscation has been used to conceal the involvement of a designated person in a transaction.

    Asset movement. The movement of assets, including the sale of high value assets that were previously associated with a designated person, by family members or otherwise on their behalf, where funds are then disbursed offshore through secrecy jurisdictions, is an indicator suspected of being used to evade sanctions.

    Unclear payment sources. It may be indicative of sanctions evasion if there is a lack of clarity on the source of payment or funds, a concealment of the ultimate beneficial owner of the goods, transactions being made through offshore accounts, or a change in payment arrangements.

    Difficulty tracing goods. It is commonplace for goods to move between jurisdictions, making such movements less noteworthy when being done for the purposes of sanctions evasion — precious metals and stones in particular are very durable and effectively untraceable.

    Digital assets. Cryptocurrencies and NFTs may be used by designated persons in an effort to circumvent restrictions applied through financial sanctions. Those using, trading in and dealing with cryptocurrencies or NFTs are also subject to these regulations and must apply due diligence.

    What Are Your Main Obligations?

    1. Due Diligence

    The onus is on you to ensure that you have put in place sufficient measures to ensure you do not breach financial sanctions. Enhanced due diligence checks on your customers and payment chains may be needed.

    Practically, this means routinely checking the UK Sanctions List — not just when you start a new client relationship, but at every significant stage of a transaction, since the list is updated continuously.

    2. Reporting to OFSI

    Reporting obligations apply to relevant firms who are required to inform OFSI as soon as practicable if they know or have reasonable cause to suspect a person is a designated person or has committed a breach. When reporting to OFSI you must include the information or other matter on which the knowledge or suspicion is based, and any information you hold about the person by which they can be identified.

    If the suspect person is actually your customer, you must also report how much in funds or assets you are holding for them.

    3. Freeze and Stop

    If you discover a client or counterparty is sanctioned, you must immediately stop dealing with them, freeze any assets you hold on their behalf, and notify OFSI.

    4. Ownership and Control

    An asset freeze and/or some financial services restrictions may apply to entities or individuals which are owned, held or controlled, directly or indirectly, by a designated person. Those entities or individuals may not be designated in their own right, so their names may not appear on the sanctions list. However, those entities and individuals are also subject to financial sanctions.

    The ownership threshold that triggers this is more than 50% of shares or voting rights, or effective control of the entity.

    What Are the Penalties for Getting This Wrong?

    The consequences are serious. OFSI has powers to impose monetary penalties of up to £1 million or 50% of the total value of the breach, whichever is higher. Breaches of financial sanctions are also a serious criminal offence, punishable by up to 7 years imprisonment on conviction on indictment, and up to 12 months on summary conviction in England and Wales.

    Failure to comply with reporting obligations is itself an offence. A person who commits this offence is liable on summary conviction to imprisonment for a term not exceeding 6 months, or a fine, or both.

    The guidance includes a real-world case study: an investigation that concluded in 2023 found that around £1 million of artwork belonging to a US-sanctioned terrorist financier was being stored in warehouses in the UK. The artwork was seized and later forfeited by law enforcement under the Proceeds of Crime Act, and a man was arrested on suspicion of terrorist financing.

    Financial vs. Trade Sanctions — An Important Distinction

    OFSI deals with financial sanctions and the Department for Business and Trade (DBT) deals with trade sanctions. These different types of sanctions have differing processes, for instance in licensing activity. It is therefore important to consider the relevance of both financial and trade sanctions to your business.

    In practice: OFSI handles the “who” (frozen assets of designated persons), while DBT/OTSI handles the “what” (restricted goods and services). A business in the high-value goods sector may need licences from both.

    ⚠️ What Changed in the May 12, 2026 Update

    The guidance was updated on May 12, 2026 — the day before the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 came into force — to reflect one substantive legal change:

    The reporting threshold currency switched from euros to pounds sterling.

    Previously, the definitions of “high value dealer” and “art market participant” referenced a threshold of €10,000. Across all UK sanctions regulations, the definitions of high value dealers and art market participants within the relevant firms regulations are being updated so that monetary thresholds are expressed in pounds sterling (£) rather than euros (€). In particular, the €10,000 threshold is being replaced with a £10,000 threshold.

    The guidance now reflects this: the £10,000 figure appears throughout sections 2.1 and 2.2 in place of the old euro amount.

    This aligns sanctions reporting obligations with upcoming changes to the UK’s money laundering regulations, so firms are not reporting in two different currencies. The Explanatory Memorandum describes this as a technical alignment measure rather than a change in policy, though the practical sterling equivalent of the old euro threshold will vary with exchange rates.

    Practical effect for businesses: If your compliance systems and internal policies referenced €10,000 as the trigger for cash-transaction reporting (HVDs) or art transaction/storage reporting (AMPs), they should now reference £10,000.

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  • May 12, 2026: OFSI makes regulatory updates

    Office of Financial Sanctions Implementation HM Treasury

    Changes to UK sanctions regulations – overview for firms

    We are writing to give you notice of changes made to the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026. The regulations have now come into force.

    What’s changed 

    Changed relevant firms reporting from euros to pounds 

    • Across all UK sanctions regulations, the definitions of high value dealers and art market participants within the relevant firms regulations are updated so that monetary thresholds are expressed in pounds sterling (£) rather than euros (€). In particular, the €10,000 threshold is being replaced with a £10,000 threshold. 
    • This aligns sanctions reporting obligations with upcoming changes to those in the UK money laundering regulations, so firms are not reporting in two different currencies. 

     Electronic notices for licences 

    • The law has been updated to confirm that OFSI and other authorities can send notices for licences electronically without needing consent for this approach. This reflects how communications already work and removes an outdated technical requirement. 

    HM Treasury debt exception 

    • A clarification that the exception for Treasury debt applies to all transfers of funds across the entire payment chain, including intermediaries. 

    Updates to the prior obligations licensing ground 

    • The SI broadens the prior obligations licensing ground, giving OFSI greater flexibility to license legitimate pre-designation obligations in appropriate cases while maintaining safeguards against sanctions circumvention. 

    FAQs updated

     Further information can be found here 

    Here are the updated Frequently-Asked Questions:

    137. If I am a HVD carrying out a transaction over the value of £10,000 via card transaction, am I exempt from reporting requirements?  

    If you are a HVD, the relevant firm reporting requirement applies only when you make/ receive a payment (or payments) in cash of at least £10,000. This therefore does not include payments via bank transfer or digital payments.

    Amended on: 12 May 2026

    138. If I am an AMP carrying out a transaction over the value of £10,000 via card transaction, am I exempt from reporting requirements?  

    If you are an AMP, the reporting requirement applies regardless of how the transaction (or series of linked transactions) is made, where the transaction has a value of £10,000 or more.

    Amended on: 12 May 2026

    and the new one:

    185. The Prior Obligations licensing ground has been amended by The Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026. What has changed in practice?

    The prior obligations licensing ground enables payments or transfers to satisfy obligations that arose before a person was designated under financial sanctions. The Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 amended this ground so that it is now applicable to a broader range of scenarios.  

    In practice, this expands the range of situations in which OFSI may consider licensing payments to satisfy prior obligations, subject to a case-by-case assessment. The change comes into force from 12 May 2026.  

    Under the amended ground: 

    1. It is no longer a condition that the funds or economic resources used to satisfy a prior obligation must be frozen under UK sanctions. 
    2. The limitations on whose funds or economic resources may be used (generally, those belonging to the DP or owned or controlled entity who owes the relevant prior obligation) have also been amended.  
    • For DPs under UK autonomous sanctions, those limitations have been removed.  
    • For UN DPs, where prior obligations licensing grounds apply, those limitations have been amended to allow the prior obligations of owned or controlled entities to be satisfied using the funds or economic resources of the DP, or of other owned or controlled entities. The assets of owned or controlled entities may also be used to satisfy prior obligations of the DP, as was the case previously. 

    Other limitations may apply, so it is important to check a specific regime to understand what may be permitted. For example, some regime-specific amendments have been made to the Iran Nuclear, Libya and DPRK regimes. Likewise, some regimes like Afghanistan do not have a prior obligation ground at all.  

    The changes do not mean that all payments relating to prior obligations will be permitted. OFSI retains discretion to refuse to grant a licence which falls within the relevant prior obligations ground even when the conditions are met, or to licence only a proportion of that obligation. For more information on OFSI’s licensing processes, please refer to our guidance.

    Added on 12 May 2026

    Here’s where those other links lead:

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  • April 23, 2026: OTSI is making updates on May 12th, too – hello, end-use controls

    OTSI header

    Sanctions End-Use Controls

    Yesterday, legislation was laid before Parliament to introduce Sanctions End-Use Controls into specified trade sanctions regimes. These powers will come into force on 12th May 2026. 

    To assist businesses, OTSI has published guidance on how these controls will be used. 

    OTSI’s website can be found on GOV.UK

    And here’s that guidance:

    Guidance

    Sanctions End-Use Controls: guidance for businesses

    Published 22 April 2026

    1. Disclaimer

    This guidance is set out to support UK businesses potentially affected by Sanctions End-Use Controls. It does not constitute legal advice. Any party in doubt about its legal position should seek independent legal advice.

    2. Foreword

    Sanctions End-Use Controls form part of the wider approach of the government to tackling the circumvention of trade sanctions. This publication is intended to help UK businesses understand Sanctions End-Use Controls that have been introduced in relevant sanctions legislation containing export prohibitions, and to support exporters to third countries where there is a high risk of diversion of goods and related technology to a sanctioned destination or person. It sets out the key features of the controls, what exporters can expect if ‘informed’ by the government that their goods or related technology may pose a sanctions diversion risk, and how to respond in practice. It also provides clarity on the intended operation of Sanctions End-Use Controls and outlines best practice around compliance, record keeping, and risk awareness. This guidance will be updated as necessary.

    3. Sanctions End-Use Controls (SEUC)

    Sanctions End-Use Controls constitute a new licensing requirement for export to a non-sanctioned third country where the exporter has been informed by the government that there is a risk of ultimate diversion of the goods or related technology, via that route, to a sanctioned destination. These controls build upon current ‘making available’ prohibitions, that make it an offence to make available restricted goods and technology to a sanctioned destination by direct or indirect means.  

    This measure will only apply to goods, or technology related to the export of a good, that are not otherwise subject to strategic export controls (i.e., items that are not included on the UK’s strategic control lists for military and dual-use items, or subject to the UK’s WMD or Military End-Use Controls).  

    Sanctions End-Use Controls are designed to: 

    • prevent sanctioned goods and related technology from reaching sanctioned jurisdictions and end users 
    • complement existing circumvention provisions under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA) 

    The government will apply this control where there are concerns around sanctions diversion risks with the end user of the good or technology.

    4. Purpose of the measure

    Trade sanctions include prohibitions on supplying specific goods and related technologies to specific locations and people. The government has seen sanctioned countries go to great lengths to circumvent our trade sanctions by purchasing sanctioned goods and related technologies via intermediaries in third countries. 

    Prior to the introduction of Sanctions End-Use Controls, in situations where the government suspected specific shipments were at risk of being diverted to sanctioned destinations, HMRC and DBT were able to advise the exporter of the risk. Once advised of the risk, it was at the discretion of the exporter whether to continue with the export.  

    Once a good has left the UK there are limited options for the government to prevent onward diversion to sanctioned people and destinations. If a sanctions breach has occurred, this is a criminal offence. However, enforcement action of such an offence takes place after the breach has occurred and cannot prevent the transfer occurring in the first place.  

    Sanctions End-Use Controls give the government the power to impose a licensing requirement on UK exporters who wish to progress specific exports, once they have been informed by the government of a high risk of the goods and related technologies being diverted to a sanctioned person or destination. This applies where such exports are not otherwise subject to export controls. Ultimately this will allow the government to assess and, where necessary, prevent exports where there is a credible risk of diversion of an item subject to sanctions to use by a sanctioned person or in a sanctioned destination. This is an important tool to tackle circumvention of trade sanctions at source.

    5. Goods covered by Sanctions End-Use Controls

    Sanctions End-Use Controls apply to all trade sanctions regimes where restrictions extend beyond arms embargoes (where the military end-use control already applies). Currently this means it applies to goods and related technologies sanctioned under the following sanctions regimes: 

    However, the requirement to obtain a licence under Sanctions End-Use Controls only applies following a process where the government ‘informs’ an exporter that their goods or related technologies and, if applicable, related technology may be at risk of diversion to a sanctioned end user, intermediary, or jurisdiction.  

    Once an exporter has been informed, it becomes a criminal offence to export those goods or related technologies without first obtaining an appropriate licence to export. Exporters who have not been ‘informed of the need for a licence should continue as normal. These regulations do not establish a blanket requirement for licensing types of goods or technologies. Exporters will be notified if the government deem a licence is necessary.

    6. What to do when you get ‘informed’

    Sanctions End-Use Controls are designed and intended to be used in a targeted way, where the government has identified a specific sanctions diversion risk linked to the good or exporter, the route, end user or intermediary. 

    If you are informed by the Department for Business and Trade (DBT), which may come through HMRC’s national clearance hub or through direct contact with DBT (through the Office of Trade Sanctions Implementation, OTSI), that your export is at risk of sanctions circumvention you will receive a written informing notice which will: 

    • identify the shipment or transaction in scope, 
    • set out that an export licence is required before the goods or technologies can be exported 

    From the point you are informed, you must not proceed with export of the goods or technologies covered by the notice unless a licence is granted. If you choose not to apply for a licence and still seek to export the goods or technologies after being informed, you will be in breach of UK sanctions law and subject to enforcement action. 

    If the goods have already been intercepted at the border, HMRC may: 

    • detain the goods while a licensing decision is made 
    • allow the goods to be returned to the exporter, pending the outcome of the licence application 

    When you are informed, you will be given information on how to apply for a licence, and any evidence you should provide to help DBT assess the risk of diversion.  

    OTSI is currently not accepting advance sanctions end-use controls licence applications. You should wait to be informed before applying for a licence. OTSI will keep this approach under consideration.

    7. When goods may be stopped at the border

    Sanctions End-Use Control powers apply to all goods and related technologies within the sanctions regimes outlined in section 3, where these are not otherwise controlled under strategic export control legislation.  

    As a general rule, the government will seek to apply Sanctions End-Use Controls to address exports that have been identified and publicised to exporters as of potential concern. the government will always endeavour to publicise known risks to assist businesses in understanding higher risk goods and transactions. 

    Currently, the highest risks identified by the government are related to circumvention of our Russia regime. The government has published guidance on the highest risk goods and export destinations in our Countering Russian Sanctions Evasion: Guidance for Businesses, which is kept up to date as patterns of circumvention change and will inform OTSI’s application of sanctions end-use controls. You can also check the Russia Common High Priority List, an internationally agreed list of Western items critical to Russian weapons systems and its military development. 

    The government uses a range of sources to inform and prioritise which exports are most at risk of circumvention. This includes, but is not limited to, publicly available sanctions evasion typologies and data indicating increased risk. Exporters are strongly encouraged to do the same as relates to their products and end users. 

    The requirement for a licence only applies where the exporter has been ‘informed’. Goods will only be subject to a licensing requirement where the government has informed’ you in writing of a specific diversion risk. This risk will be assessed on a case-by-case basis.  

    OTSI does not intend to impose blanket licensing requirements for a specific type of good going to a specific destination but reserves the right to do so, should the need arise.

    8. How to apply for a licence

    If you are informed under Sanctions End-Use Control powers, you must apply for a licence before proceeding with the export of the goods or technologies covered by the informing notice. 

    Find out how to submit a licence application to the Office of Trade Sanctions Implementation (OTSI). 

    Applications will be assessed on a case-by-case basis by DBT, working closely with other departments as needed. Factors that could be considered include: 

    • the nature of the good or related technology and its potential uses 
    • the diversion risks associated with the customer, route or end-user 
    • the exporter’s compliance history and due diligence processes 
    • any additional intelligence available to HM Government 

    Possible outcomes include: 

    • the licence is granted, and the export may proceed subject to any licence conditions 
    • the licence is refused, and the goods or technologies may not be exported to the end-user or route identified 

    The complexity of the case and the availability of information will affect how long it takes to reach a decision. Exporters are encouraged to submit detailed, complete and accurate applications as early as possible after receiving an ‘informing’ letter to minimise potential delays.

    9. Information needed for a licence application

    Further information on applying for a trade sanctions licence can be found at the following link: 

    10. Record keeping and due diligence requirements

    Sanctions End-Use Controls do not change your record keeping or due diligence expectations. If exporting goods or related technologies, you are expected to conduct adequate due diligence to demonstrate compliance with UK sanctions. If you are informed, you may be asked to supply details of your due diligence and a licence for export will be granted if you can satisfactorily demonstrate that your goods are not ultimately destined for a sanctioned destination. 

    For more information on due diligence please read our countering Russian sanctions evasion – guidance for businesses. While this guidance is Russia-specific, much of the advice can be applied to other UK trade sanctions regimes.

    11. Penalties for non-compliance

    Failure to comply with the licensing requirement pursuant to a notice issued under Sanctions End-Use Controls is a breach of trade sanctions and may result in enforcement action. 

    Possible consequences include: 

    • detention or seizure of goods by HMRC at the border 
    • revocation or refusal of existing and future export licences 
    • being publicly named under OTSI’s powers to name companies who breach sanctions  
    • a report about the breach being published by OTSI 
    • OTSI imposing a monetary penalty 
    • criminal investigation and potential prosecution 

    HMRC is responsible for the enforcement of trade sanctions within its role as the UK customs authority. This applies to goods that cross the UK border and strategic goods and technology (as well as services ancillary to those movements). HMRC also criminally investigates relevant breaches referred by other agencies. OTSI leads on the civil enforcement of sanctioned services, as well as trade in sanctioned goods, technologies and services outside the UK, where a UK person is involved. OTSI can refer cases to HMRC to consider criminal investigation.  

    In some circumstances, monetary penalties may be imposed on a strict liability basis. This means that a monetary penalty can be imposed even where the person did not know or have reasonable cause to suspect that they were in breach of sanctions.  

    Exporters are encouraged to cooperate fully with any enquiries by HMRC, OTSI or other enforcement authorities and to seek legal advice where appropriate.

    12. Case studies

    Sanctions End-Use Controls apply to exports to non-sanctioned destinations where the exporter has been informed by the government that the export is at risk of diversion to a sanctioned destination. During the licensing process it may be determined that this risk is minimal and therefore the government is content with the onward export of these goods or related technologies. In these circumstances, a licence will be issued for the export of these goods or related technologies. If, however, the exporter ignores the informing letter and proceeds with the export without applying for a licence, this would constitute a criminal offence.

    12.1 Case Study 1: Licence refused after being ‘informed’

    For example:

    A UK company exporting industrial cooling systems to a Central Asian third country distributor is informed by DBT that the goods are likely to be re-exported to a sanctioned Russian entity. The goods were stopped at port by HMRC and the details referred to DBT for assessment. The company then receives a letter requiring them to apply for a licence under the Sanctions End-Use Controls. The goods are either held or can be returned to the customer pending a decision. These goods cannot be exported to the end user until the outcome is determined. The application is refused due to diversion concerns. The company updates its due diligence procedures and stops trading with that distributor.

    12.2 Case Study 2: Licence granted after being ‘informed’ 

    For example:

    A UK trader applies for a licence to export precision electronics to a Middle Eastern country after being stopped at customs and informed. During the licence review, the exporter provides clear information on the end use of the products that indicates a reduced risk of diversion. The exporter is issued with a licence for these goods, and the export can continue its onward journey. 

    12.3 Case Study 3:  Continuing with an unauthorised export after having been ‘informed’  

    For example:

    A freight forwarder receives an informing letter about a consignment of bearings due for export to a company in the Caucasus region, raising diversion concerns. The letter makes clear that an export licence is required before proceeding. The forwarder overlooks the letter and exports the shipment. The company is investigated for breach of Sanctions End-Use Controls, and risks enforcement action as set out in section 8.

    13. Further information

    13.1 Goods are not being banned for export

    Sanctions End-Use Controls are a targeted mechanism that only apply once you are informed of specific risk factors. If informed, you must apply for a licence before exporting. 

    13.2 Differences between SEUC and existing catch-all controls

    The UK’s existing end-use export controls apply where there are specific risks that an item might be used for the production of WMD or for a military end use in a country subject to a full or partial arms embargo. Sanctions End-Use Controls focus on goods and related technology not subject to these controls (e.g. where they are not for export to a country subject to a full or partial arms embargo), but where there is an identified risk of circumvention of an export subject to sanctions for use in a sanctioned destination or by a sanctioned person.  

    13.3 Comparison of UK sanctions end‑use controls and the EU catch‑all provisions

    The UK SEUC are similar to the EU’s “catch-all” provision in that they both provide powers to impose licensing conditions on goods to prevent circumvention, however, sanctions end-use controls apply across all sanctioned goods in all sanctions regimes, whereas the EU’s “catch-all” provision applies only to the highest risk goods within their Russia sanctions. 

    13.4 Applying for a licence where there is a risk of diversion

    If you believe your goods are at risk of diversion to a sanctioned destination , you should consider not carrying out the transaction. You are strongly encouraged to undertake further due diligence before proceeding and you may also wish to seek legal advice. Sanctions regulations prohibit direct and indirect supply, so you may be at risk of a breach of sanctions regulations if you proceed with a transaction where you have reason to believe the goods are ultimately intended for a sanctioned jurisdiction or person. 

    OTSI is not currently accepting advance licence applications but will keep this under review. You should wait until you are informed before submitting a licence application. If you suspect that your export may be in scope of Sanctions End-Use Controls and have determined that you wish to proceed.  In any event, the licensing process should not be used as a replacement for substantive due diligence. To speed up the process you are encouraged to provide as much information as possible during the licensing process. For more information please read our guidance on applying for a licence from OTSI.

    14. Contacts and further information

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  • April 21, 2026: Global Affair Canada guidance for the aerospace and defence sector

    Here’s a summary of the new guidance:

    Summary: Canadian Sanctions Guidance for the Aerospace & Defence Sector

    Source: Global Affairs Canada (last updated April 20, 2026). No additional sources were used.

    What This Is

    This is a guidance document from Global Affairs Canada aimed at helping Canadian aerospace and defence organizations understand and comply with Canadian sanctions laws. It is not a legal opinion — the government recommends that organizations maintain their own internal compliance program and consult legal counsel when needed.

    Who It Applies To

    When Canada imposes sanctions, all persons in Canada and Canadians abroad face restrictions on dealing or collaborating with sanctioned countries, or with specific listed individuals and entities. This includes aerospace and defence companies involved in importing, exporting, or providing services related to goods and technologies.

    Export and Import Controls

    In some situations, a transaction may legally require both an approved export control permit and a separate sanctions permit. Even if you hold a valid export permit, a transaction involving a listed person is still prohibited without a sanctions permit. Similarly, if the destination country is subject to sanctions — even if none of the parties involved are listed — a sanctions permit may still be required.

    Dual-use goods (items that can serve both civilian and military purposes) receive particular attention. Certain dual-use goods and technologies may be prohibited under specific sanctions regulations.

    Russia and Belarus are specifically highlighted. Regulations targeting Russia and Belarus prohibit the sale or supply of many goods and technologies (regardless of whether they could be used to make weapons), services related to aviation and aerospace, and research or technical assistance.

    Canada is also a member of the Global Export Control Coalition (GECC), which monitors battlefield-bound goods through a Common High Priority Items List (CHPL). Canada has incorporated these items into its Russia sanctions regulations.

    Arms and Related Material

    Under Canadian sanctions law, “arms and related material” broadly covers weapons, ammunition, military equipment (including military vehicles), paramilitary equipment, and their spare parts.

    When assessing whether something qualifies, the guidance says to consider: whether the good is specially designed or modified for military use; whether its intended end use supports a military program; whether it is going to a military entity or defence contractor; and whether the transaction might benefit a listed person with military connections.

    Related service prohibitions may also apply, including financial services, insurance, and other services tied to the manufacture and export of prohibited goods.

    Due Diligence

    Sanctions in Canada change frequently. Companies are encouraged to:

    • Screen proposed engagements against the UN Security Council Consolidated List and Canada’s Consolidated Autonomous Sanctions List.
    • Look beyond direct dealings — under most relevant legislation, it is prohibited to facilitate a transaction related to a listed individual or entity, even indirectly through a third party that may not be Canadian and may be located outside Canada.
    • Ask questions such as: Does my client have ties to listed persons, through family members, subsidiaries, or intermediary banks? Does this activity benefit a listed person in any way?

    Red Flags

    Some individuals and entities may attempt to circumvent Canadian sanctions. If a transaction raises red flags, companies should ask: Can the red flags be explained? Can you confirm the legitimacy of the parties and the transaction? If doubt remains, legal advice is strongly recommended.

    Enforcement

    Information on reporting sanctions violations and penalties for non-compliance is available through Global Affairs Canada’s sanctions enforcement guidance. Questions can be directed to the Global Affairs Canada Sanctions Bureau.

    Confidence Check

    Everything in this summary is directly supported by the source page. No claims were extrapolated or inferred beyond what the document states. I did not use any additional sources. One important caveat: this is a summary of government guidance, not legal advice — the page itself notes that organizations should consult private legal counsel for their specific situations.

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  • Burning Question: The march of time (and minimizing sanctions evasion)

    so, I asked Gemini to build the story of sanctions evasion-related advisory and guidance documents. Its response:

    The latest advisory from March 31, 2026, titled “Guidance on Sham Transactions and Sanctions Evasion,” signals a new frontier in the U.S. government’s efforts to stop illicit actors from hiding their wealth. By reviewing this document and the history of OFAC’s guidance, we can see a clear evolution: sanctions have moved from simple “do not trade with this person” lists to complex “detective manuals” that require companies to spot sophisticated lies.

    Part 1: Summary of Today’s Advisory (March 31, 2026)

    Verified Document: Guidance on Sham Transactions and Sanctions Evasion.

    The core message of this document is that a “paper trail” is no longer enough to prove a transaction is legal. OFAC is warning that blocked individuals—such as sanctioned Russian oligarchs or international drug kingpins—are using “Sham Transactions” to pretend they no longer own their luxury assets (like private jets, yachts, or companies).

    Key “Red Flags” for Sham Transactions:

    • Family Transfers: A sanctioned person “sells” or transfers an asset to a spouse, child, or close associate shortly before or after being sanctioned.
    • Below-Market Deals: Selling a multi-million dollar asset for a tiny fraction of its value, or on terms that don’t make business sense.
    • Invisible Control: The sanctioned person “sells” their private jet but continues to use it for personal travel, meaning they still effectively own it.
    • Unnecessary Complexity: Using layers of shell companies in “tax haven” countries to hide who really benefits from the property.

    Part 2: The Evolution of Sanctions Evasion Guidance

    Over the last decade, OFAC’s guidance has evolved through four distinct “generations.”

    1. The “Who” Era (Foundational / Pre-2019)

    In this era, compliance was relatively simple: don’t do business with anyone on the SDN List (Specially Designated Nationals).

    • The Big Rule (2014): OFAC clarified the “50 Percent Rule,” stating that if a sanctioned person owns 50% or more of any company, that company is also automatically sanctioned—even if its name isn’t on a list.
    • The Evasion: People began splitting ownership into 49% chunks to stay “under the radar.”

    2. The “How” Era (2019: The Framework)

    OFAC realized that companies needed a “playbook” to avoid making mistakes.

    • Key Document: A Framework for OFAC Compliance Commitments (May 2019).
    • Evolution: This established the “5 Pillars” of a good compliance program: management support, risk assessment, internal controls, testing, and training. It told companies: “We won’t just look at who you trade with; we will look at how hard you tried to follow the rules”.

    3. The “Behavioral” Era (2020: Global Maritime Advisory)

    Sanctions evasion moved to the high seas, where bad actors began using “Deceptive Shipping Practices” (DSPs).

    • Key Document: 2020 Global Maritime Advisory.
    • Evolution: Guidance shifted from “Lists” to “Patterns”. Companies were told to watch for ships turning off their GPS (AIS), “spoofing” their location, or transferring cargo between ships in the middle of the ocean (STS transfers) to hide the cargo’s origin.

    4. The “Detective” Era (2023–2026: Shadow Fleets and Sham Deals)

    The current era is defined by the war in Ukraine and the “Russian Oil Price Cap”.

    • The “Shadow Fleet”: Guidance now focuses on “Ghost Ships”—older, poorly maintained vessels with fake insurance used to bypass oil price limits.
    • “Know Your Cargo” (2023): A landmark “Quint-Seal” note (issued by five agencies) told companies they must now verify the cargo, not just the customer.
    • The Latest Step (Today): The 2026 “Sham Transactions” advisory completes the circle. It warns that even when the person looks clean and the ship looks clean, the legal paperwork might be a lie.

    Summary for Non-Experts: How the “Rules of the Game” Changed

    Old Way (2016)New Way (2026)
    “Check the List”: If the name isn’t on the SDN list, you are probably fine.“Check the Vibe”: Even if the name is clean, you must ask: “Does this deal make sense? Why is this ship’s GPS off?”.
    “Simple Ownership”: Just check if a sanctioned person owns 51% of a business.“Ultimate Control”: Check if they secretly control it through a trust, a shell company, or their spouse.
    “Bank Responsibility”: Mostly banks and financial firms had to worry about this.“Industry Responsibility”: Insurers, ship captains, freight forwarders, and luxury goods dealers are now on the front lines.

    Today, OFAC treats every company as a “mini-detective agency.” If you ignore a red flag—like an oligarch suddenly “giving” his yacht to his wife for $1—the government can hold you responsible for “sham” activity.

    So, what do you think? The inclusion of the Framework Document seems a bit of a curveball (certainly I didn’t expect that to pop up), but it seems to follow a certain logic….

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