Trade sanctions: civil enforcement
How trade sanctions are enforced by the Office of Trade Sanctions Implementation (OTSI).
This guidance relates to the Office of Trade Sanctions Implementation (OTSI). OTSI will be able to exercise enforcement powers under The Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 when it comes into effect on 10 October 2024. UK persons and businesses will need to comply with the new legislation from that date.
This guidance is produced by the Office of Trade Sanctions Implementation (OTSI), part of the Department for Business and Trade (DBT) which is the authority for the implementation of certain trade sanctions in the UK.
OTSI has powers to enforce certain trade sanctions under the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024.
These pages set out OTSI’s approach to enforcement.
This guidance is general, so you should also refer to the relevant up-to-date legislation.
This guidance does not represent legal advice.
If you are unsure about your obligations in any given case, you should consider taking independent legal advice.
It is your responsibility to ensure you are compliant with the requirements of legislation.
Trade sanctions and OTSI
OTSI has the power to investigate suspected breaches and take enforcement action in relation to trade sanctions relating to:
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providing or procuring sanctioned services
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moving, making available, or acquiring sanctioned goods outside the UK
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transferring, making available or acquiring sanctioned technology outside the UK
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providing ancillary services to the movement, making available or acquisition of sanctioned goods outside the UK
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providing ancillary services to the transfer, making available or acquisition of sanctioned technology outside the UK
OTSI also has powers to investigate and enforce breaches related to the trade sanctions measures set out above, regarding:
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circumvention, such as intentionally facilitating the contravention of sanctions
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exceptions, such as failing to comply with the notification requirement of an exception
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information requests, such as intentionally obstructing an information request from OTSI
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recordkeeping, such as failing to comply with recordkeeping requirements of a general licence
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reporting obligations, such as a relevant person failing to comply with their obligations to report suspected breaches
OTSI will consider each case on the facts and the specific legal requirements that apply.
There are other types of trade sanctions which are implemented and enforced by HMRC, HM Treasury or Ofcom: these are not subject to OTSI’s powers.
Breaches of trade sanctions
Your obligations to supply information
For providers of legal or financial services, or a money service business
Overview of sanctions
General information on UK sanctions and why we have them, from FCDO and DBT.