UK Trade Sanctions Office imposed no civil penalties in 2025-26 despite over 170 breach reports

LONDON, September 1, 2026 — The UK Office of Trade Sanctions Implementation imposed no civil monetary penalties during its first full reporting year, despite receiving 178 reports or referrals concerning possible trade sanctions breaches.

OTSI said in its 2025-26 annual review that it ended the financial year with a “substantial” number of investigations at an advanced stage, with several expected to reach decision points during 2026-27. Its civil enforcement powers took effect in October 2024 and cannot be applied retrospectively.

Russia-related cases accounted for the overwhelming majority of potential breaches reported to OTSI. Of the 178 cases received between April 1, 2025, and March 31, 2026, 156 related to the UK’s Russia sanctions regime. Four each concerned Belarus and Iran, while smaller numbers involved Myanmar, North Korea, South Sudan and Syria.

Financial and other sectors subject to mandatory reporting requirements accounted for 111 reports, or 62% of the total. OTSI also received 25 voluntary reports and 23 referrals from other UK government departments or agencies.

OTSI closed 104 enforcement cases during the year. It found no breach and took no further action in 41 cases, while 40 were closed by OTSI and referred to HM Revenue & Customs. The referrals included cases involving possible criminal enforcement as well as suspected conduct predating OTSI’s enforcement powers.

The agency said about 6% of cases opened during the year were initiated proactively through its own intelligence-led work and that it intends to increase that proportion.

OTSI also received 51 sanctions licence applications during the year, of which 50 related to Russia. It granted 17 applications and refused two, while other cases were withdrawn, closed or determined not to require a licence. The average processing time for completed applications was 96 working days.

Since April 2026, OTSI’s remit has expanded to include most trade sanctions licensing and new Sanctions End-Use Controls designed to prevent goods exported through third countries from being diverted to Russia or other sanctioned destinations.