UK Enforcement Agency Hints at Penalties, Preparing for More Licensing Work
One year after being created, the U.K.’s Office of Trade Sanctions Implementation has “a number of investigations” underway and has received nearly 150 referrals or reports involving possible sanctions and export control violations, the agency said in its first annual report.
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OTSI, which launched in October 2024, hasn’t yet imposed any civil penalties, but the agency suggested that’s expected to change soon. It plans to provide “further details on OTSI’s enforcement activity” in next year’s annual review.
OTSI said it has so far referred “a significant number of cases” to the U.K.’s customs agency and other governments, and it wants to pursue more “proactive enforcement.” It plans to develop new capabilities to “use actionable intelligence to support proactive compliance monitoring,” the report said. “We are also looking at how we can better share and join up intelligence analysis across government departments.”
Along with enforcing U.K. trade sanctions, the agency oversees licenses for certain activities and services prohibited under the country’s trade sanctions laws. It received 60 license applications through Oct. 9, and the “vast majority” involved Russia-related services that would normally be blocked, it said. So far, OTSI said, it has granted or partially granted 12 and refused three. Seven were withdrawn, one application didn’t need a license, and five applications were submitted “in error.”
OTSI said license reviews are averaging 82 working days, including the time that applicants take to reply to requests for information. The agency plans to publish more guidance on licensing to “help applicants better understand our processes and improve the information they provide, which in turn is intended to help expedite the licence assessment process.”
OTSI also is taking responsibility for “all export sanctions licensing” in early 2026, except for certain technology subject to the U.K.’s strategic export controls, which will still be overseen by the Export Control Joint Unit.
“Exporters will be informed when this change will happen and what it will mean for them,” OTSI said. “We will strive for minimal impact on businesses using the service.”