Committee publication · Correspondence · 14 April 2026
Letter from the Minister of State for Trade relating to the enforcement of UK trade sanctions, 27 March 2026
From: Business and Trade Sub-Committee on Economic Security, Arms and Export Controls
Inquiry: The UK's trade sanctions regime
Summary
Minister of State for Trade Sir Chris Bryant responds to the Business and Trade Sub-Committee's questions on UK trade sanctions enforcement, addressing overlap between sanctions lists and export controls, the Office for Trade Sanctions Implementation's staffing, historical arrest data, end-use licensing regimes, and ISDS exposure. The letter clarifies that OTSI employs around 40 full-time staff and HMRC has arrested 24 people since 2013 on sanctions/export evasion offences.
Key findings
- OTSI currently has approximately 40 full-time equivalent staff covering compliance, licensing, guidance, outreach, and policy
- Since 2013, HMRC arrested 24 people suspected of sanctions or export evasion offences: 14 for sanctions breaches and 10 for Strategic Export Control breaches
- End-use licensing for sanctioned goods will operate on a case-by-case basis, administered by OTSI working with the Export Control Joint Unit and HMRC, and requires secondary legislation planned for this session
- The Common High Priority List includes civilian and mass-market products not subject to formal export controls; the UK focuses counter-circumvention efforts on products identified through HMRC data analysis as likely diverted to Russia
- The government states it has never faced a successful ISDS claim and maintains it acted consistently with domestic and international law in challenged cases, declining further comment due to ongoing proceedings
Tone
ProceduralTopics
Key actors
Sir Chris Bryant MP, Liam Byrne MP, HMRC, Office for Trade Sanctions Implementation (OTSI), Department for Business and Trade, Export Control Joint Unit, FCDO
Notable line
“Since 2013 HMRC has arrested 24 people on suspicion of committing offences relating to being knowingly concerned in the evasion of sanctions or Strategic Export controls.”
Key Quotes
“There are currently around 40 full ‑ time equivalent members of staff in core roles in OTSI covering compliance, licensing, guidance, outreach, and policy.”
“Since 2013 HMRC has arrested 24 people on suspicion of committing offences relating to being knowingly concerned in the evasion of sanctions or Strategic Export controls. 14 of the arrests were in relation to sanctions offences and ten were in relation to Strategic Export offences.”
“It will apply on a case-by-case basis, similar to existing military end-use controls.”
“The UK has a longstanding track record of supporting foreign investment, including through fulfilling its obligations in the international investment agreements to which it is a party and has never faced a successful ISDS claim.”
Source · parliament.uk record ↗