Committee publication · Correspondence · 25 March 2026

Letter to the Minister of State for Trade relating to the enforcement of UK trade sanctions, 13 March 2026

From: Business and Trade Sub-Committee on Economic Security, Arms and Export Controls

Inquiry: The UK's trade sanctions regime

Summary

The Business and Trade Sub-Committee on Economic Security, Arms and Export Controls writes to the Minister of State for Trade following his 25 February evidence session on UK trade sanctions enforcement. The Committee requests detailed information on sanctions oversight structures, a new end-use licensing regime for sanctioned goods, coherence of Russia energy sanctions policy, and risks posed by investor-state dispute settlement mechanisms to sanctions effectiveness.

Key findings

  • Committee seeks clarification on overlap between Common High Priority List and Strategic Export Control List, organisational structure of the Office for Trade Sanctions Implementation, and 15-year arrest data for sanctions evasion offences.
  • Government announced an end-use export licence regime for sanctioned items not already controlled; Committee requests operational details, scope (including intangible goods), implementation timeline, and resource allocation.
  • Committee expresses concern about delays in promised legislation to ban import of refined Russian oil products and questions exemption of Transneft's Druzbha pipeline from recent sanctions.
  • Government maintains multi-billion pound gas supply contract with TotalEnergies despite company's continued links to Russian gas industry; Committee questions renewal decision and policy coherence.
  • Russian oligarch Mikhail Fridman has challenged UK financial sanctions via investor-state dispute settlement mechanism; Committee seeks risk assessment and mitigation steps to prevent weaponisation of bilateral investment treaties against sanctions regime.

Tone

Procedural

Topics

trade-sanctionsexport-controlsrussia-ukraineinvestment-treaties

Key actors

Sir Chris Bryant MP, Liam Byrne MP, Mikhail Fridman, Department for Business and Trade, Office for Trade Sanctions Implementation, TotalEnergies, Transneft

Notable line

It would effectively allow bilateral investment treaties to be weaponised, through international arbitration tribunals, against a key UK foreign policy objective.

Key Quotes

Sanctions targeting Russia's energy sector are one of the key levers for the UK and its partners to reduce the Kremlin's ability to wage its illegal war on Ukraine.
Liam Byrne MP · Introducing concerns about coherence of UK Russia energy sanctions policy
It would effectively allow bilateral investment treaties to be weaponised, through international arbitration tribunals, against a key UK foreign policy objective.
Liam Byrne MP · Describing risks posed by investor-state dispute settlement challenges to sanctions regime
We also note that the Government's recent sanctions against Russian pipeline companies contain a significant exemption for Transneft's Druzbha oil pipeline in Europe.
Liam Byrne MP · Questioning inconsistency in application of Russia energy sanctions
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Source · parliament.uk record ↗