UK issues guidance on new sanctions end-use export controls
Britain has published guidance on its new sanctions end-use controls, setting out when exporters to third countries may need a licence if goods risk diversion to a sanctioned destination or person.
LONDON, April 22, 2026 — The UK government has published new business guidance on Sanctions End-Use Controls, or SEUC, describing a targeted licensing tool meant to stop sanctioned goods and related technology from being routed through non-sanctioned third countries to banned end users or jurisdictions. The guidance was issued by the Department for Business and Trade and the Office of Trade Sanctions Implementation.
Under the regime, a licence requirement only arises when the government formally “informs” an exporter in writing that a specific shipment or transaction presents a diversion risk. Once informed, it becomes a criminal offence to export the goods or related technology covered by that notice without first obtaining a licence. Exporters that have not been informed should continue as normal, and the government says the measure is not a blanket licensing requirement.
The controls apply to goods and related technologies sanctioned under a range of UK regimes, including Belarus, North Korea, Iran, Libya, Myanmar, Russia and non-government-controlled territories of Ukraine, Somalia, Syria, Venezuela and Zimbabwe, where the items are not already covered by strategic export controls. The government said the highest current circumvention risks are linked to Russia-related trade sanctions evasion.
If HMRC or DBT informs an exporter that a shipment is at risk, the exporter must halt the export unless a licence is granted. Goods may be detained at the border or returned pending a licensing decision. OTSI said it is not currently accepting advance SEUC licence applications, meaning companies should wait until they receive an informing notice before applying.
The guidance also underscores that due diligence and record-keeping expectations remain in place. Non-compliance can lead to seizure of goods, licence refusals, public naming, monetary penalties and possible criminal investigation or prosecution. In some cases, monetary penalties may be imposed on a strict liability basis.
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