Committee publication · Correspondence · 24 February 2026
Letter from the Minister of State for Trade relating to the enforcement of UK trade sanctions, 16 February 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 detailed questions about UK trade sanctions enforcement. The letter reports that the Office of Trade Sanctions Implementation (OTSI) has opened 185 investigations and closed 117 cases since October 2024, with at least five cases at advanced stage for enforcement action. HMRC has opened 101 investigations since 2022, resulting in eight compound settlements totalling £2.5m. The government outlines its compliance and enforcement architecture, capacity building, and coordination with international partners.
Key findings
- OTSI has opened 185 potential breach investigations since launch (October 2024–end 2025) and closed 117 cases (63%), with 14 cases (8%) proactively initiated and 30 cases (16%) from voluntary disclosure routes.
- HMRC has opened 101 investigations into trade sanctions breaches since 2022; 83 stemmed from self-reported disclosure, with 22 criminal investigations opened, of which 2 have been referred for prosecution resulting in 3 criminal charges to date.
- Eight compound settlements totalling £2,524,855.13 have been imposed by HMRC, with the largest being £1,160,725.67 in May 2025 for Russia-related sanctions breach.
- OTSI currently has approximately 40 full-time equivalent staff in core roles; the government estimates joint UK, US, and EU sanctions measures have deprived Russia of over $450 billion since February 2022.
- Government commits to separate reporting of sanctions versus strategic export enforcement actions in the 2025 ECJU Annual Report, and HMRC will publish anonymised case studies on enforcement breaches to improve business compliance.
Tone
FactualTopics
Key actors
Sir Chris Bryant MP, Liam Byrne MP, Office of Trade Sanctions Implementation (OTSI), Her Majesty's Revenue and Customs (HMRC), HM Treasury's Office of Financial Sanctions Implementation (OFSI), Department for Business and Trade (DBT), Export Control Joint Unit (ECJU)
Notable line
“OTSI is progressing a number of active investi- gations towards conclusion, and has used the insights from incoming reports to improve guidance for businesses and highlight best practice.”
Key Quotes
“The Government remains fully committed to robust and effective implementation of trade sanctions, including those targeting Russia's ability to sustain its illegal invasion of Ukraine.”
“Between 10 October 2024 when OTSI launched and the end of 2025, OTSI opened inves- tigations relating to 185 potential breaches of trade sanctions.”
“In the same period, OTSI closed 117 cases (63%) of potential breaches of UK trade sanc- tions. Cases are closed for a variety of reasons, including no breach being identified, or referral to other enforcement bodies or regulators, including HMRC …”
“Timely vol- untary disclosure of the suspected breach by the individual or business responsible could lead to a reduction of up to 50% of a monetary penalty imposed for the breach.”
“… at least five investigations are at an advanced stage where it appears that a breach of sanctions regulations has occurred.”
“HMRC is resourced sufficiently to deliver this policy for sanctions breaches. In recent years we have strengthened our capabilities for detecting and enforcing sanctions breaches, in- cluding via investment provided by the FCDO's Economic Deterrence Initiative Portfolio.”
“HMRC assesses that it has disrupted at least 11 individual supply routes.”
Source · parliament.uk record ↗