Guidance

Appealing a civil monetary penalty for a breach of trade sanctions

How to request a review and how to appeal to the Upper Tribunal.

What OTSI must tell you

If the Office of Trade Sanctions Implementation (OTSI), which is part of the Department for Business and Trade (DBT), has made a decision to impose a civil monetary penalty on you for a breach of trade sanctions (after they’ve informed you of their intention to do so and considered any representations you may have made), they must tell you: 

  • what their decision is 

  • that you are entitled to seek a review 

  • the date by which you must tell OTSI whether you want a review 

Requesting a review

If you request a review, the Secretary of State (or a delegated authority such as a minister or a senior official who is unconnected with the original decision) will review the monetary penalty.  

They may decide to: 

  • uphold the decision to impose a penalty and its amount 

  • uphold the decision to impose a penalty, but increase or lower the amount 

  • cancel the decision to impose a penalty 

Appealing to the Upper Tribunal 

You must seek a review before you can appeal to the Upper Tribunal.  

If you’re unsatisfied with the decision, you may appeal to the Upper Tribunal. 

If you choose to appeal to the Upper Tribunal, it may: 

  • uphold the decision to impose the penalty and its amount 

  • uphold the decision to impose the penalty, but increase or lower the amount of the penalty  

  • quash the decision to impose the penalty 

Find out how to appeal to the Upper Tribunal

Get help

Contact OTSI using the enquiry form.

Updates to this page

Published 12 September 2024
Last updated 10 October 2024 + show all updates
  1. This guidance is now in force, so the banner saying it is not in force yet has been removed.

  2. First published.

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