Guidance

Report a suspected breach of trade sanctions

Tell us if you think you, or someone else, may have breached trade sanctions.

If you breach trade sanctions, you may face enforcement action, which could include criminal prosecution or a civil monetary penalty.

How to report a suspected breach

How you make a report will depend on which trade sanctions measures you think have been breached, as you’ll need to report them to the correct organisation.  

Certain trade sanctions measures are implemented and enforced by the Office of Trade Sanctions Implementation (OTSI), which is part of the Department for Business and Trade (DBT). Most others are enforced by HM Revenue & Customs (HMRC), except the oil price cap (HM Treasury) and internet service measures (Ofcom). 

This page explains which trade sanctions breaches you should report to OTSI and which to HMRC. You can then: 

  • use the online service linked from the button on this page to report to OTSI 

  • find out how to report to HMRC  

There are specific rules for reporting if you’re a provider of legal or financial services or a money service business.

Who to report to

Report these suspected breaches to the Office of Trade Sanctions Implementation (OTSI

Use the online service on this page to tell OTSI if you think you, or anyone else, have breached trade sanctions by:   

  • providing or procuring sanctioned services 

  • moving, making available or acquiring sanctioned goods outside the UK 

  • transferring, making available or acquiring sanctioned technology outside the UK 

  • providing ancillary services to the movement, making available or acquisition of sanctioned goods outside the UK 

  • providing ancillary services to the transfer, making available or acquisition of sanctioned technology outside the UK

Report these suspected breaches to HMRC

Report other types of trade sanctions breaches to HMRC, including those related to: 

  • the import or export of goods to, or from, the UK 
  • the transfer of technology to, or from, the UK 
  • the provision of ancillary services relating to the import and export of goods and the transfer of technology to, or from, the UK 
  • goods and technology, such as military and dual-use goods and technology, which are subject to strategic export controls

If you have imported or exported goods or transferred technology without an appropriate export licence, you should report this to HMRC as soon as possible. This is informally called a voluntary disclosure. Find out how to make a voluntary disclosure to HMRC.  

If you discover or suspect that another person or business has breached any of the trade prohibitions or licensing provisions related to importing or exporting, you can report this to HMRC. Do this as soon as possible, using HMRC’s online service to report tax fraud or avoidance to HMRC.  

Report to the Office of Trade Sanctions Implementation (OTSI)

Report yourself or someone else (voluntary disclosure)

If you think you, or someone else, may have breached trade sanctions, you should report it.  

If you’re reporting about yourself or your business, your voluntary disclosure may be a mitigating factor in OTSI’s assessment of the case. For example, it may reduce the level of any civil monetary penalty OTSI may impose. 

If you’re a provider of legal or financial services (also known as a relevant person), you have a legal obligation to report a suspected breach of the trade sanctions that are enforced by OTSI.  

Read more about reporting obligations for providers of legal or financial services

Report to OTSI using the online service

You cannot currently use this service to report a breach anonymously. 

If you’re reporting as a third party and you need to report several unrelated businesses which you’re representing, you must submit a new report for each business. 

Start now

If you’re unable to use this service, contact OTSI.

What happens next

OTSI will review your report. They may need to get in touch with you for more details before they can decide if there has been a breach.  

If your report concerns a breach committed by yourself or your business, and there has been a breach, OTSI will inform you of any action they may take. If there has not been a breach, they’ll inform you that they’re closing the case without action. OTSI cannot give a timescale for this due to the complexity of some cases. 

How OTSI can share information you supply

OTSI may share information you supply, including sharing with other departments, agencies and international partners, in accordance with the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024, data protection legislation and the Report a suspected breach of trade sanctions privacy notice.

If you have acted, or are acting, as counsel or solicitor for a person or business, any information you provide does not require you to disclose any privileged information in your possession.

Other reporting obligations

Reporting to OTSI is in addition to any other sanctions reporting obligations you may have. These could include reporting to the Office of Financial Sanctions Implementation (OFSI), reporting required by your regulator (if you have one) or submitting Suspicious Activity Reports (SARs) to the National Crime Agency (NCA) under the Proceeds of Crime Act 2002. 

Get help

Contact OTSI using the enquiry form.

Updates to this page

Published 10 October 2024

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