Business and Trade Sub-Committee on Economic Security, Arms and Export Controls — Oral Evidence (2026-02-25)
1/97Welcome to today’s session of the Business and Trade Sub-Committee on Economic Security, Arms and Export Controls. We thank you, Sir Chris, and your officials for joining us today. This week, we mark the terrible fourth anniversary of Russia’s full-scale invasion of Ukraine. However, UK components are still turning up in drones that are fired at the brave Ukrainians. Last year, we imported potentially billions of pounds of oil products made with Russian oil. This afternoon, Sky News is reporting that tankers are sailing through the English channel with up to $100 million-worth of oil on board. How are we still in a position where we have not shut down all trade of any sort—direct and indirect—with President Putin’s war machine?
First of all, let’s acknowledge that it was the fourth anniversary yesterday, and we introduced a new set of sanctions yesterday, which we will perhaps come on to. It is true that the Russian bear is a wily fox—to mix my metaphors—in the sense that the Russians have sought to avoid and evade all our sanctions every step of the way. We have had to make sure that we constantly update that process and bring new elements into it. We have had some significant successes. Some 99.6% of Russian imports to the UK have stopped. We behave slightly differently from Russia in regard to humanitarian issues; we still export pharmaceuticals and foodstuffs to Russia, because we believe that that is a humanitarian issue and that we should not be taking the war to the civilian population in Russia. All of this has had a big effect on the Russian economy. Something like 41% of their federal budget is now spent on the war. They have 16% interest rates and 8% inflation, and Putin himself has acknowledged that it has had an effect. But I do not want to pretend that we will not always have to keep on ratcheting up the pressure. That is why, yesterday, for instance, in relation to some of those who have been facilitating the Russian shadow fleet, we introduced sanctions against a western group that had been providing insurance for it. We had also already sanctioned 520 fleet vessels, and we added another 40 or so yesterday. We have tackled the pipeline and in last October and December increased our action against Russian oil. In relation to crude oil that is refined, you used the word “potentially”. You are quite right Mr Byrne that we do not know the precise amount of Russian crude oil that might have been refined in other countries and then brought to the UK. However, that is one of the statutory instruments that we will be laying very soon, precisely to tackle oil refined in other countries and then brought into the UK. You also asked why things made in the UK still end up in Russian drones. If you will allow me a slightly lengthy answer, we have three lists that deal with all of this. First, there is the export control list, which does not just apply to Russia, but anywhere applies to anywhere in the world where we have export controls for military and dual-use equipment. We also have the common high priority list, which is a whole series of things. The second list is the things that are sanctioned. Both of those lists are agreed between ourselves, the US, the EU and Japan—so they are shared. We then have our own specific list, which is taken out of those lists. There are some things that we do not produce, so it is unlikely that they would be going into the supply chain anywhere in the world. There are issues where we know we have problematic or potentially problematic items or sectors, and countries or jurisdictions where we need to work hard to ensure that things are not being diverted to Russia. We do not have controls for everything. There will be some things that might have entered the stream because they were sold long before the war in Ukraine, or simply because they were not on either of those two international lists. The other element is that, while we have worked very hard with industry and other countries to make sure that there is no diversion of material that is licensed or allowed to go to other countries and through into Russia, I can none the less announce today that we will introduce legislation to make sure that we tackle sanctions end-use controls. That is where we would be able to insist on people getting a licence before they are able to export for anything that we think might be problematic because of where it will eventually end up.
I see. That is very helpful. Is it the case at the moment that not every item on the common high priority list is subject to strategic export controls?
Yes, they are two different things.
What is the overlap between the two at the moment?
In terms of a percentage?
There are about 100 things on the common high priority list. How many of those items are subject to strategic export licences?
I do not know the answer to that question. Does anybody?
The classification is a little different because of the way that export controls, the codes and sanctions work. It is not a precise match. There is some overlap, but we would have to take away the question of the precise percentage. There is certainly some.
It strikes me that if the west has agreed a list of common high priority items that we think should not be allowed into Russia, there is a strong case for looking hard at whether they should all be subject to strategic export controls to deny them ever going—either directly or indirectly—to Russia.
That would not necessarily deal with the problem that some newspaper stories have come up with, because some of those are items that would not be on either list because they are so generic. Some of the things that have been found to be in Geran-2 drones, for instance, are things that you would find in children’s toys. I am not sure that it would necessarily answer the problem that we may have, but I am happy to consider it. The thing that we consider most clearly is whether there are things that the UK does not produce at all, and therefore it is unlikely that we will need to take action on them.
What therefore is the point of having a common high priority list?
Because we have determined that there is a whole series of things that we do want to sanction, and we want to make sure that they do not get through into the Russian economy. We have done that on a joint basis and I think that is important to do wherever we possibly can. All these countries have wanted to debilitate the Russian military complex—and that is what our aim is—by denying them either cash or matériel.
If there is, as you just said, a case for ensuring that common high priority list goods do not go to Russia directly or indirectly, then presumably there is a case—I put it no stronger than that—for ensuring that all of those items are subject to strategic export licensing controls.
I will turn to my officials in a moment. I want to reserve my position a little, because we already control quite a lot of things and we do thousands of licences every year. One of my concerns, as I have expressed to the Committee before, is about making sure that we are making timely decisions on those licences. If we were to increase the number of things that would require licences, would that be proportionate to the damage that we would be dealing with, and where would we find the resources to do that swiftly enough?
If you are reserving your position on strategic licensing, which is fair, what are the other ways in which you will ensure that common high priority list items do not get into Russia—if they are made here?
This is the sanctions list. It is a criminal offence for them to be provided by the UK. As I say, some of those things are not produced in the UK at all, so it is not an issue for us, but they are produced by other countries on the list that I mentioned.
Could you perhaps give us your analysis of the common high priority list items that are subject to strategic export licensing controls at the moment and are subject to other kinds of controls that you are exercising, so that the Committee can see whether there is a set of items that are, if you like, sanction-free or export licence-free?
Everything on the common high priority list is sanctioned.
It is sanctioned.
End of.
Perfect.
It is just that we do not produce some of those items. That is why we have our own bespoke list of things about which we are most concerned, because we do produce them and they might be going to other countries. Some items might be in a sector significant to us. They are still sanctioned things and we are trying to make sure that they are not diverted to Russia via a third country such as Kazakhstan. I met the Kazakhstan Foreign Minister this morning and that was one of the things we discussed, and I am meeting him again tomorrow. We have a list of territories that are of concern to us. That is the situation at the moment. When we can introduce the legislation on sanctions end-use controls, that will mean that items going to those countries, if we are concerned, would have to be licensed. They are not sanctioned to go to Kazakhstan, but they are sanctioned to go to Russia.
I will bring in Alison Griffiths at this stage, but I will come back to the question of trade diversion in a second.
I want to go back to the point about new sanctions coming in on the fourth anniversary. The key question I have is: why wait until the fourth anniversary, which in all honesty, while an emotional and symbolic date, is actually arbitrary? If the additional sanctions are needed, surely they should have been imposed earlier. Once those new sanctions have been imposed, what else is in the toolbox, and when will it be deployed?
We tend to produce packages of sanctions, partly because it makes it easier for those watching this space—industry and the sector—to understand exactly what is happening. You could argue that we should identify each ship one by one, but we think it is better to do it in a package. You are right: in one sense, the date is arbitrary, but we have introduced a series of packages. I think that this is the ninth series of packages—I am looking to HMRC here, but I should really be looking to the Foreign Office.
It is the ninth in terms of statutory instruments, but we have done many more packages of designations on individuals and companies as well.
So what is the gap in-between? What is the trigger that pushes you to the next stage?
First, the world changes, and we note different versions of diversion or evasion of sanctions, so we want to make sure that we tackle that. That is particularly in relation to the Russian shadow fleet. It is not just that we wanted to tackle the fleet ships themselves, but one of the things we spotted more recently was the insurance that is providing for them, which we have taken action against. Likewise, in October—the Foreign Office will correct me if I have got that wrong—we took sanctions against four major crude oil producers in Russia. We added another four in December, and we are now tackling the pipeline. Sometimes it is just when we spot something new. We try to do it as swiftly as we can. We often try to work as closely as possible with our international allies, just because there is obviously a slight danger that if we take action and somebody else does not, it diverts the evasion to another territory.
Let me just round off on the topic of the common high priority list. Presumably, the Government have a pretty good map of the supply chains that go into producing anything that is on the common high priority list in the UK.
Yes.
That did not sound terribly convincing.
No, because I am not sure where you are going with this.
There is a way of enforcing that we are not clear that the Government are pursuing. We can see that there is a pretty tried and tested system of farming data coming in from banks and other financial institutions, which appears to account for a significant number of the investigations that are triggered. The alternative approach to farming data is going out and hunting people who are breaking the rules. Proactively reaching out to the companies in the supply chains that produce common high priority list items in this country, and trying to track down bad behaviour and warn people in the supply chain is a different approach to enforcement. I am interested in the enforcement model that we are now operating to make sure that the controls on the common high priority list are as tight and ferocious as they need to be.
If you look at some of the common high priority list—I have got it here; it is quite extensive, and I will obviously not go through all of it—it includes photosensitive semiconductor devices, transistors other than photosensitive ones, and diodes. It is a fairly specific list. Some of that is produced in the UK, and we are rigorous about that. When somebody is applying for a licence, it is a different matter from when they know that they are being sanctioned. Jo, you look like you want to say something.
Yes. In conjunction with DBT colleagues and others, we undertake quite a lot of outreach and awareness-raising for industry to educate them on risk and issues. In particular, we undertake targeted engagement with exporters if we think that their exports may be at high risk of diversion, which includes such things as the export of luxury and dual-use goods. We highlight the risks, ask them to be careful with their due diligence, and to know their supply chain and customers. That engagement has generally been positively received, and through it, we have stopped 46 shipments. We have also assessed that it has disrupted at least 11 individual supply routes and networks for illicit supplies.
Thank you for that, but my question is a bit simpler: have you got a list of people who make the stuff on a common high priority list, and have you proactively reached out to all of them to make sure that they understand their obligations?
Yes.
Great; that is a nice, clear answer. Let me now turn to trade diversion—
Actually, would it be useful for me to say which are the jurisdictions where we recommend extra due diligence?
That would be very helpful, although I will come on to trade diversion in a second.
I will do it whenever you want.
Let’s look at a slideshow of data that you will be very familiar with. When we look at machinery exports from the UK to Armenia, we can see a large spike after the war and the second invasion began. Similarly, in exports to the Kyrgyz Republic, there was an extraordinary increase of exports into Russia and there is a similar pattern in Uzbekistan. We are interested in what you are doing to try to make sure that exports from the UK to one of these three countries are controlled, if it is blindingly obvious that they are then going on to Russia. Let’s try to bring this to life a little bit by saying that I am making machine goods or cranes in the UK. I am sending them to my traditional dealers in Turkey or the UAE, but I have a pretty good sense that those dealers are then shipping the stuff into Russia and there is evidence that it is being used either on the battlefield or in reconstructing war damage in Russia. What are the obligations that bite on the UK manufacturer in circumstances such as those?
First of all, as you just said, we have a good knowledge of the people who would be engaged in making such things, and the list that I was about to talk about starts with Armenia and includes Kazakhstan, Kyrgyzstan, Uzbekistan, Türkiye, Thailand, Serbia, India, the UAE, Vietnam, China and Malaysia. In each of those countries, we have already shown extra diligence. That is the situation as it applies now, and when you and I visited central Asia in 2023, we saw some of that and we talked to people about it. The Foreign Secretary is having meetings with all five countries of the C5 today and tomorrow around some of those issues and we have much better co-operation now, I would say, than we did back in 2023. Just because cranes are being sold to Uzbekistan, it does not necessarily mean that they are going to Russia. The big difference that we will be able to make now, under the legislation that we are intending to bring in in the very near future—the sanctions end use controls—is that, if somebody is manufacturing cranes and sending them to Uzbekistan, we will be able to say, “You have got to get a licence to be able to do that”. I know that the Committee has been thinking about and pushing for that, and it is one of the things that we are taking action on, on the back of your—
That is significant progress. Am I breaking the law today if I am making a crane and selling it to my traditional dealers in the UAE, safe in the knowledge that they are probably sending it on to Russia?
“Safe in the knowledge” is quite an interesting phrase to use there. If you are knowingly and/or, I think, recklessly—or should it be “knowingly and recklessly”?
Definitely “knowingly”.
If you are knowingly expecting it to go to Russia, then you would be breaking the law. That is an offence.
So to prove that I am not doing that knowingly, what do I need to do?
At the moment, you would talk to us; when the legislation comes in, you will have to seek a licence and be able to prove where it is going to go and where it is going to stay. I can give another ECJU example: say you were producing protective vests and you were selling them to the police force in another country. You would need to get a licence, and one of the questions we might ask you is, “Where is that going to be used?”. If it was going to be used in an area to enable repression, then you would not get the licence.
So at the moment, I commit an offence if I am sending goods to an intermediary knowingly, in a way that allows them to go to Russia—
If you are knowingly evading sanctions, then you are breaking the law on sanctions and that is a criminal offence.
And there are probably know your customer rules that I ought to be going through today—but the new legislation is basically going to put this beyond doubt.
Completely, because you will have to apply for a licence for any of those. Obviously, the precise legislation is still to be laid, but we intend to do so as soon as we can.
In this Parliament? Or do you think that will be a King’s Speech measure?
You mean in this Session? I do not know the answer to that. That is normally for the Chief Whip and the Leader of the House to decide.
But you are expecting to do that this year?
Yes. I want to do it as soon as possible.
Going back to the pipeline in the package, as per your announcement yesterday, targeting one of the world’s largest oil pipeline companies, PJSC Transneft, which is responsible for transporting over 80% of Russian oil exports—this is the ninth package. Why was that not in the first package? I do not understand. That is huge. It is stationary and obvious, so why have we taken nine sanctions and four years to sanction something that has enormous amounts of money coming out of it for the Russians?
If I can very briefly defend the previous Government, back in 2022—for all sorts of reasons that were discussed in the Foreign Affairs Committee—it was unclear to some members of the Government whether the UK was creating a new sanctions-developing policy of its own after Brexit or not. Sometimes we proceed alongside our EU colleagues as closely as we possibly can. We do the same with the US as well. I do not know why that specifically was not addressed before, but the Foreign Office might.
In total, we have gone through more than 3,000 sanctions designations under the Russia regime so far. In the energy sphere, that has progressively included more and more of the Russian oil sector. In particular, that involved getting the four Russian oil majors done by last autumn. Some 80% of Russia’s oil flows through pipelines that Transneft operates. It has taken some time to get to the point of doing that sanction, partly because, as time goes on, we assess the impact of our sanctions and the risks to market stability. Back in 2022, when we first started putting sanctions in place, there was a spike in the oil price, which is very counterproductive to the aim of our sanctions. We have proceeded by covering more and more of the Russian energy sector over time as we assess what the likely consequences of doing so will be. We now see that the global market has enough capacity that we can go further and do more.
I am resisting pulling up a four-year oil price chart right now, but we could do that. The oil price has moved around a lot in that period. I find it very weird that we are choosing to continue to not sanction a massive pipeline coming out of Russia with oil in it on account of markets. I do not think that that is what our country wants to happen. What on earth has been going on for four years? We keep saying that we are sanctioning Russia, but this huge pipeline is gushing oil into Europe and into the UK, presumably. Or is that not into the UK?
No, it is not into the UK.
Okay, so all the more reason to be sanctioning it. We should be setting an example to our European allies to say, “We are sanctioning it. Get on with it.”
We have taken a leadership role where we can, but the truth of the matter is that we have not always been able to take all of our European colleagues with us.
Do we have to, on something like that?
Well, it is better.
Why not lead?
It is better when we do take our European colleagues with us; it is just more effective. Similarly, we added 175 entities that are part of the illicit two rivers trading network yesterday. I could read your comments as welcoming the fact that we announced that yesterday, but I take the point about working at pace. I mean it when I say that I sympathise with what you are saying.
Is it possible to get a list of what is still not sanctioned?
No, and it would be a very bad idea for us to publish such a thing, because we obviously want to reserve our right to be able to take further action wherever we can spot it. Sometimes the fact that we have spotted it is something that we do not want to make public until we take the sanctions measure.
Fair enough, but what about publishing a set of principles for why you are not sanctioning things? Clearly, you have known about things like this pipeline for a long time, so that is not an oversight. You have made the decision not to sanction it—perhaps that was right—but there a whole load of other things that you are also presumably putting on the “ratchet up” list that are not being sanctioned. Is palladium on there? Is fertiliser on there? Are we really keeping Russian exports of fertiliser open? Maybe you would like to answer that. Are we?
I do not know the answer to that question. Again, it will be difficult to produce an argument for why we are not sanctioning something without effectively recommending people to use it and, for that matter, producing a list of things that we might be thinking of sanctioning in the future. The bigger point I would make is that we have done a pretty comprehensive job. It is always going to be a constant ratchet up, and I am sure there will be other things that we spot in the next six, nine or 12 months. I hope that we will not need to do this in a year’s time, because we will reach a ceasefire, but I am sceptical.
I would be more confident if we did not have a pipeline with 80% of Russia’s oil exports coming out of it that two days ago was still not on that list—that is a big, chunky thing. Is that by far the biggest asset, or are there other assets of that size that have still not been sanctioned by the UK?
I think that is for the Foreign Office.
I would say no. Having sanctioned all the oil majors, and this specific company that runs the Russian pipeline system, I would say that there is nothing of comparable size.
Metals? Fertilisers?
We have banned a lot of metals through our different statutory instruments, and I believe fertilisers are part of the exemption for foodstuffs and related goods for the sake of global food security.
We are still taking fertiliser from Russia because we need its fertiliser.
No—99.6% of all imports from Russia to the UK have been stopped. Sanctioning is different from preventing imports.
Are we able to have broad categories to say, “We are still not sanctioning metals or fertiliser”?
I am not going to produce a list of things that we are not sanctioning—I think that would be a complete own goal.
Why?
Because it is effectively declaring our impotence in some regard, and it would also imply that we think we should sanction in this area but are choosing not to. I think it is an odd request, if I am honest.
But, Sir Chris, there are some strategic sectors where we have said, as a country, that we are not going to implement sanctions, such as life science products.
Pharmaceuticals and foodstuffs.
You said at the top of the meeting that there will be some goods that we do not want to ban exports of, so Mr Maynard is then asking what are the goods or services that we are still importing from Russia.
We are not—we have removed 99.6% of all imports. I can try to find out what the 0.4% is, if you want, but we have been about as comprehensive as possible. I have heard the comments made in previous debates about us relying on Russian oil and gas, but that is simply not the case.
I will come back to oil derivatives in a second, but can I just bring in Mr Cooper on this point?
Thank you, Chair. You were talking there about the shutting down of imports. I am concerned about fish, because I was astonished to find that we actually are importing Russian fish, although perhaps not knowingly because it seems to go via China. Russia ramped up its exports into China; one figure I have seen says that they rose by 15% after the invasion to something like £2.5 billion-worth of fish going to China. At this point it seems to be washed and becomes Chinese, and it then comes into the UK largely in the form of block fish, which I think goes into things like fish fingers. That is sanctions dodging, isn’t it? This is a cash crop for Russia.
It is sort of the equivalent of the diversion that we are trying to tackle, where we sell something from the UK to a third country and it then goes into Russia—there is another version, just as is there is with oil; that is why we are taking action on crude oil that is refined in other countries, which will similarly be banned from import into the UK. I note that the word you used earlier, Mr Byrne, was “potentially”, because they do not know the precise figures, and we do not know them either—by definition, in a sense. It is a decent point that you are making, but I do not have specific numbers or details on that. If you do, we would be grateful to have them. I am not sure whether anyone else has them.
I do not have details on fish, but we are certainly checking imports for sanctions. We made 30 seizures in relation to sanctioned imports, and we also have two ongoing import-related criminal investigation cases, as well as two more that are being scoped. We are definitely taking enforcement action on the small remaining percentage of imports.
Just to explain, HMRC has responsibility for any goods that cross in or out of the border, hence why HMRC is here. OFSI is also Treasury, OTSI is us in DBT, and sanctions policy lies with the Foreign Office.
Anything further on that specifically, Mr Cooper?
No, thanks, Chair.
Let’s come to oil derivatives then.
We talked about this in the Chamber a couple of weeks ago. India is importing oil and gas from Russia, and it has a number of refineries—I think four out of five are state-owned, with the fifth being Reliance. It is processing its oil and gas into petrochemical products and exporting them, including to the UK. Essentially, we are receiving a mixed bag of various petrochemical products, some of which are Russian, into the UK. The Europeans have shut down that trade, but we have not. You have said, “by spring”, but the windows are open today and it is warm. Can you say whether it will happen by recess? There is a war on. I am not trying to give you a hard time individually; I know you are very keen to get it shut down, but we really need to get this shut down as fast as possible. We should not be buying this product.
I completely agree. We are taking that action, and it will happen very swiftly. I am always slightly hesitant about timetables because, in my 25 years in Parliament, I have never known a Minister manage to deliver a timetable for putting legislation on the statute books that they thought they could deliver. I do not know whether my DBT colleague wants to say more.
As you say.
In the end, the actual timing ends up being down to the Leader of the House and the Chief Whip.
I think “very swiftly” was the phrase you used.
It was.
It is quite close to “imminently”, but it is not quite.
These are words that have been used—for that matter, so is “spring”. I hate to go back to Julie Andrews, but I have confidence that spring will come again.
Is the UK supportive of a full maritime services ban on Russian-related products or not?
I cannot remember where we are going on that. Where are we going on that? That is for the Foreign Office, I think.
We have spent a lot of time with our European colleagues on this, and we can see the ambitions of the maritime services Act that they are proposing. We understand that our American colleagues are not quite there yet, but we want to try to make sure that at least the UK and the EU are joined at the hip on this.
Yes. We would support moving to a full maritime services ban on Russian crude oil and refined oil products, working with international partners. We continue to discuss that with the Europeans.
That is the Europeans, but what about the Americans? Does that mean we would not do it without the Europeans, but we are okay to do it without the Americans?
We moved in October and December without the Americans, but with the EU.
We would like to work with as many international partners as possible, but yes, particularly the EU.
Just looking a little bit further than maritime services, we have a big services economy in finance and insurance. How confident are you in shutting down the relationships on finance between Russia and UK, which have been very substantial? How much is that being shut down?
A lot of Russian banks have already been sanctioned. From the very early days, there was a large amount of disinvestment in Russia, prompted by the sanctions regime that we had instituted. I have already referred to the fact that one of the effective facilitators of the shadow fleet is the insurance mechanism, and that is one of the things that we have now taken action against. Frankly, it is quite shocking that that exists in the west as it is. To answer your question, of course we would always like to be able to take all our international partners with us. When we are entirely on our own, it is less effective, but, whether it is us and the US or us and the EU, we want to be able to proceed where we can.
So if the EU is up for it, we will not let American reluctance get in the way of acting.
That is right.
Give us a sense of the timetable on which you hope to move. You can go anywhere—you can pick a season, or you can say “imminently” or “very swiftly”. Give us a sense of your ambition.
Can I pick a year? I am very reluctant to give a timetable, unless the Foreign Office has a timetable in mind.
I think we would like to move as soon as possible, but it is dependent on European partners.
The Graham Bill is also making progress in the United States Congress. Do you have a sense of how much of a gap there is between sanctions legislation in Congress and here? We know that some colleagues in Congress are trying to get tougher on sanctions. Are we keeping pace with them? Is that an analysis we have done?
Obviously the US is a mixture of processes, because you have Congress and then you have the Administration. Trying to make all that work in harmony is an important part of what we are doing. I am not aware of us being behind Congress on any particular pieces of legislation, but, again, it is a Foreign Office responsibility.
The Graham Bill includes a whole range of different measures, including a lot of things on tariffs, for example. We do not always coincide on exactly the same measures, but we have co-ordinated with the US on the objective of raising economic pressure on Russia and we continue to do so.
Before we move on to enforcement, I just want to round out the conversation on particular goods and particular countries. We wrote to you about the Cygnet case. I do not necessarily want you to comment on the Cygnet case specifics, but thank you very much for your letter, which was welcomed. I think you are reviewing the licensing decision that was made in that case.
Can I say two things about that?
I was just going to ask you a broader question about the case. The substance involved was prepreg, which essentially goes into making drone wings. For me, it provoked the question of how you look in the round at items that we need to prohibit based on what we learn on the battlefield.
That is a constant process. If I am honest, I am grateful to journalists when they manage to dig up stuff that we have not been able to spot ourselves. It is a helpful process, not one that I want to criticise at all. If the decision is made that Cygnet needs to get a licence because the substance is on the controlled list, it will have to go through that process and prove where it is going and so on. But nothing has thus far shipped.
I take your point about journalists being useful. You have probably seen “Bypassing the Blockade: How Hong Kong Feeds European Technology Into Russia’s War in Ukraine” by the Committee for Freedom in Hong Kong Foundation. Very helpfully, there is a list of UK exports going through to Russia. Even more helpfully, there is a list of trading companies that have been sanctioned, or not sanctioned, by the UK and various other countries, and it shows how much they are selling. It might be worth a conversation. I don’t really know this and I would love to hear your thoughts. When you get something like this, obviously you have to verify it, but if you do verify it, how long does it take you to shut those companies down and get them on a list that tells people not to trade with them?
I will let others come in in one sec, but in relation to Hong Kong, I think I am right in saying that only a couple of months ago, a director of a UK firm was sent to prison for exports of controlled goods to Hong Kong without a licence.
When we use sanctions designations to take action against a bad actor involved in sanctions circumvention, how long it takes to build the case depends very much on the circumstances. We have to investigate what we know about it and what the evidence backs up, and we have to build and rigorously test whether there is a legally robust case for making that decision. It is then a decision for Ministers.
I am going to ask, “How long is a piece of string?” because there is a war on and there is quite a lot of information in that. You might not be able to validate everything perfectly, but there might be enough circumstantial evidence to say, “Well, this is a bad enough actor that we want to be stopping this.” Do you have to have perfect evidence or you cannot move, or do you just make some informed decisions?
The evidence does not have to be 100% perfect, but there must be reasonable grounds to suspect that it is an involved person under the terms of the sanctions regime. Of course, we have to juggle all the possible options for designations and prioritise within that.
To make a quick complementary point, there are also trade sanctions. If there is an activity, good or service going to a sanctioned destination that it should not go to, or if there is some sort of diversion risk, that is where OTSI and HMRC would come in potentially with an enforcement role, as well as an educational and deterrence role. We would use that report, among many open-source pieces of information and sources of intelligence, to build a picture—we do an awful lot on building that picture. We would then do proactive outreach to companies in the UK that may be interacting with those entities. There is a network and set of complementary actions that we can use—designations, trade sanctions and enforcement. We can work together with a whole range of things to work out the best way of tackling this.
Of course there may be malefactors, and we obviously seek to chase them down, either through HMRC’s activities or through our own. But in the vast majority of cases, industry works closely with the Department to get to a good set of outcomes. In truth, it is a complex mix, because we have financial sanctions, trade sanctions, transport sanctions and immigration sanctions. That whole mix is quite complex for some people to negotiate.
You are about to get end-use licensing as well, with your new Bill. Let us turn now to enforcement.
The Office of Trade Sanctions Implementation, or OTSI, looked the business at the start. It was supposed to crack down on companies dodging Russian sanctions and ensure that companies that were found to be dodging strict trade sanctions would face tougher penalties. Where are we, 18 months in? Looking at it from the outside, we are not seeing much enforcement action. It also seems heavily reliant on self-reporting, and obviously if you are a bad actor, you will not be turning yourself in. What difference has OTSI made?
First of all, OTSI has only had 18 months, and it is obviously not able to investigate things that happened before its powers came into operation. I would expect the number of instances to go up over future years, rather than down. About five cases are quite close to conclusion and could lead to substantial measures being taken. You are right that it is self-reporting, but it is mandatory self-reporting. We made sure in the legislation that things that OTSI could take action on would be reported to it. A significant number of cases have either been closed because there is nothing to pursue or referred directly to HMRC or other Government Departments to take further action. I am confident that it is operating effectively, but it is part of a suite of operations. It works very closely with HMRC. Given all that pattern, I think the enforcement of our sanctions regime is pretty effective; I would argue that it is more effective than in any other country that I have yet seen.
So we may see the results on HMRC’s scorecard, rather than on OTSI’s.
Yes—I have the numbers somewhere. We have had 185 potential breaches reported of which five, as I said, are at a late stage, 117 were closed and 57 were reported to HMRC. Does HMRC want to take up the baton?
In 2025, we had 42 referrals from OTSI, 19 of which are still under review regarding which action we are going to take. For eight, there was no further action, either because when we looked into it there was no evidence of an offence, or because it was below our criminal threshold. Seven cases, however, link to existing HMRC investigations, which we are using information from OTSI to support. We also had a further two referrals that had already been referred to HMRC as voluntary disclosures. We referred one case to the NCA because it fit better with theirs and, I think, they might have had a related case. Then five of those referrals were deconfliction checks from OTSI to make sure that nothing they might do would conflict with work that HMRC already had in hand.
Minister, you talked about the suite of options that you have. It is very interesting that, in May last year, the Government said they would explore the possibility of cross-departmental joint sanctions intelligence function—which sounds like the old phrase “joined-up thinking”—to underpin all this sanctions enforcement. What progress has been made on that? Do you have a cross-cutting or overarching body that is drawing together the strands of this suite?
When we came into office in 2024, one of the things that we said that we would do was review the whole sanctions regime. Some of the decisions that were made yesterday were made on the back of that, and some of the announcements that we are going to be making in the next few weeks, and some of the legislation that we will be introducing, will be because of the review that was done last May. That is when the comment was made. Anna will say a couple of words in a moment, but my impression is that we work very closely between all the different organisations. I am not sure that I want to create an additional committee or anything like that.
To build on that, each of the enforcement bodies have their own intelligence function of one kind or another. We have been looking at improving the join-up across that. That is already working very well—the way that our different intelligence functions work across a whole range of enforcement agencies such as HMRC, OTSI and OFSI. We are all working together better already because there was a clear impetus, and a clear call to action, to do more there. That is really driving an increase in our proactive enforcement work—I think across the board, it would be fair to say. We are looking at what further steps we might want to take to go further with that join-up, but we are certainly already working closely together and reaping the rewards of sharing intelligence and working more efficiently. That is already bearing fruit in some of the operational work that we are all doing. It is something that we hope to say more on as we develop that work further, but there is certainly already really excellent join-up as a result of that recommendation coming out.
Again, Minister, to go back to what you said about how we measure ourselves against other countries, how do we do that? We obviously want to avoid marking our own homework or believing the stories that we tell ourselves about ourselves. How do you measure our performance against other countries?
That is why I was somewhat hesitant in the way I said it, because to be honest, it is only anecdotal. I have not seen any categorical definition of different countries’ activities. We try to work closely. Of course, the majority of our historic sanctions regime was operated through the European Union, though we still had an independent right to take sanctions separately from the EU, as we did in relation to Iran. But in the main, this is something that we have got up from scratch since Brexit.
Anna, the Minister kindly wrote to us on 16 February setting out what was quite a comprehensive set of replies about the capabilities of OTSI. You have about 40 staff now, is that correct? What have been the biggest challenges in putting that team together? Broadly speaking, Minister, is it now at the right size in your judgment?
It is broadly speaking at the right size. Obviously, it is going to be taking on some additional responsibilities in the near future, and we will need to review to make sure that we have the right number of people for it.
Okay. Anything to add, Anna?
No, nothing to add.
The number of cases that have been proactively opened by OTSI is 14, which I think is about 8% of the total cases that have been opened. That sounds quite low. Of the 40 people that you have, how many are proactively investigating sanctions breaches?
That question is a bit more for you, Anna, operationally.
I don’t think it is possible to give a clear answer on that. The way that we are set up means that we work across different functions in OTSI, so I am hesitant to give a definitive number for the people working on proactive enforcement. All 40 people are, in one way or another, supporting our efforts to move towards more proactive enforcement. That is obviously a ramping-up exercise, and we fully expect that 14 to increase quite dramatically over time as we do more proactive enforcement. The mandatory reporting we get is incredibly rich. It is from financial institutions and legal firms, both of which are involved in trade transactions, contracts and financing. The material that we get through those reports is incredibly rich. It is helping us to build our proactive enforcement repertoire and to drive that forward. While in some cases it is self-reporting, sometimes it is third-party reporting. Either way, it is a really rich picture. It is a novel area, because we have not had mandatory reporting in trade sanctions enforcement before the creation of OTSI, so it is a very rich seam that we are looking to mine further.
In that case, maybe we can ask you for an organisational breakdown of OTSI, just so we have a sense of who is doing what in there. We can do that in correspondence.
We will give you whatever we can. My only sensitivity is that we do not want to expose any—
State secrets.
Yes—well, not state secrets, but stuff that might enable those who want to evade sanctions to do so.
Fair enough.
My question is to the Minister and Joanne: HMRC is, as I understand it, responsible for criminal sanctions enforcement, and one of the legal bases for that is section 68 of the Customs and Excise Management Act 1979, or CEMA. Subsection (2) covers the “intent to evade”. That is the more serious offence where a person is “knowingly concerned” in the export of goods with the intent to evade a prohibition or restriction. How many people have been arrested for that in the last 15 years?
I do not have figures on numbers arrested. We have 21 live criminal investigations. Of those, we recently had two charging decisions, and there are three individuals in those two cases.
Just to be clear, you will know that in many instances what HMRC moves towards is a compound settlement, but it would not do that in relation to the issues you are talking about, because that would be a case of deliberate evasion, and then it would not use compound settlements.
I want to park compound settlements. Anecdotally, I have been told—I do not know whether this is true—that there have been two arrests in the last 15 years. Obviously, that was under a different Administration, but would you mind checking and telling us how many individuals have been arrested on that basis?
We will write back to you.
Because if it is anything like that, obviously we have a really big problem. There are an awful lot more bad actors than that. That means HMG has not been doing what it should have been.
Or you could argue that it means the legal threshold is inappropriate and needs to be changed, or whatever—
Whichever way, we have a really big problem.
It is a perfectly legitimate point, and I am very happy to write to you about it.
I want to go there, because I am worried that we have a massive gap in enforcement and bad actors probably know that. If we are serious about sanctions enforcement, we need to close that gap really fast. I do not know what the answers are, and I am not expecting you to have them all, but let’s get the facts open so that we know what the state of play is.
I am happy to do that.
Charlie, do you want to move on to compound settlements?
Yes. First of all, it is a weird euphemistic term, which I did not understand. Somebody described it to me today as “shakedowns”; I am not over the shoulder on that one, but essentially somebody says, “I’ve made a technical error,” and you say, “Yes, you have, and we’ll have some money for that, please.” They hand over the money and then it is quits, and that is possibly all right—but if that is all that is going on, ultimately, my sense is that people are doing tens or hundreds of millions-worth of bad-acting stuff with Russian oil and gas, swimming around on a massive scale. When we have got our entire compound settlements—and that is it, because there is no HMRC enforcement in terms of money that we have received information on—of £2.5 million over four years, and we think about the scale of the war in Ukraine, I feel disappointed and worried.
I know. First of all, I want to say that I think the vast majority of our sanctions are holding and UK business and UK financial institutions and everybody are abiding by them. I think that is an example of success. I am not complacent about that. I want to do everything I possibly can to make sure that Putin does not win and so on. On compound settlements, I am about to stray beyond my knowledge, probably.
Don’t let that stop you, Sir Chris.
You have saved me many times, Mr Byrne. Compound settlements are part of the way HMRC do a lot of their business. For instance, if there was an investigation into your income tax, they might come to a compound settlement as well. There are legitimate questions to answer, but—
Just before you go on, let me frame it in this way. The evidence that we have taken from a range of experts in this field delivers two points. One is that the risk of a compound settlement that does not name the perpetrator means we do not have the proverbial heads on spikes and therefore we lose a deterrent effect, which is a tried and tested practice in the United States. OFAC has been pursuing that kind of strategy for a long time very successfully. The second issue, as Mr Maynard says, is that when we look at the total number of pound notes received in compound settlements, it looks quite low, given the kind of evidence that we hear about the scale of sanctions evasion. We are concerned as a Committee that compound settlements undermine the deterrence of the enforcement activity being undertaken, and we are not sure it is on the right scale.
If I answer the first bit, Jo will answer the second bit. There is a perfectly legitimate question around whether we should not be publishing more details not just about the nature of what has happened, but so we are naming and shaming people. There will undoubtedly be an advantage to doing so because of the deterrent effect that you have referred to. The downside is that, by definition, a compound settlement is a sort of agreement with the other party. If that then prevented them from coming to an agreement, we might be in a process where we were going to pursue legal action, which might not be successful and would incur significant costs for Government as well. I incline towards greater transparency. One of the things we are looking at is how we can achieve that over the next few months, because I take that first point.
Say more about that. What do you mean by looking at?
I am not Treasury. HMRC would have to make a determination about whether they could go in that direction. And there is another problem for them, which is that many of these issues are subject to quite tight confidentiality issues—not because we have insisted on it, but because of the whole premise on which the reporting is done. They have to be able to work their way around that legal element. Jo is probably better equipped to answer some of that.
We have very much been listening to and have heard the concerns about the transparency around compound settlements. We recognise that greater transparency can be helpful in terms of deterrent effects and in terms of lessons learned for other companies and individuals to see what has happened. We are currently bound by strict taxpayer confidentiality. It is not specific to sanctions or strategic exports. That is part of our wider confidentiality that HMRC operates under in relation to taxpayers’ affairs. We are looking at options for what more information we can currently put in the public domain. We are also looking at options for giving ourselves greater legal powers to name. That is in the early stages of work at the moment.
And it would require legislative change, just to be clear. That is my anxiety about the pace that we might be able to move at on that.
Yes, and under the current constraints under which we are operating, we are moving to make more compound settlements with the condition that the person or company agrees to be identified, in appropriate cases where we think that that is justified. One of those might be that the company itself has put some information in the public domain already.
It is obviously a problem if the state has decided to delegate enforcement activity to a part of Government that has to work in such secrecy that the deterrent effect is completely undermined.
I want to get to greater transparency, and get there as fast as possible. It is not directly within my Department, but it is one of the things that I want to drive forward.
Okay. I am taking away from this conversation that you are looking at this, and you will come back to us or to Parliament with a decision.
We would have to come back to Parliament because it would require legislation. I am not even sure whether it would be primary or secondary legislation.
We are seeking advice on what legislation would be needed, so I cannot answer that at the moment.
You are reviewing legislative options.
We are, yes.
I want to ask very quickly about cryptocurrency. This will be a debate that comes up a lot on Monday in the elections Bill, with regard to cryptocurrency donations and political finance. For the purposes of our session today, I want to get a take from you on what the scale of the problem is with cryptocurrency donations as an enabler of sanctions evasion. What is the casework telling you about this problem?
Go on, Anna.
It clearly is an issue, and it is something that OFSI and the Treasury have been looking at and driving some cross-Whitehall work on. It is obviously something that we are alive to, and it is an increasing part of the wider financial crime picture. We are aware of it and alive to it, and we are working with partners across Government. In particular, the Treasury is leading some work on this that we are docking into. We will be looking out for this; there is clearly a trend.
I am interested in you characterising the nature and scale of the problem based on the casework you have at the moment. Is this a big problem, a little problem or a marginal problem?
It would be difficult for me to speak in any meaningful way about how it is featuring in our casework. It is certainly something that we are aware of. We know that others are seeing it too; there is a collective view that this is a growing issue that we need to tackle, and we are going to tackle it. I am not in a position to speak more precisely about how it is feeding through in our casework, but it is absolutely something that we are looking out for and looking to build a picture on, to then play that back to the industry so that they can improve their compliance and due diligence efforts.
There are some particular platforms that have been named in open-source reporting on this, including Tether. Are there other particular flavours of cryptocurrency that appear to be turning up more often than others?
I was simply going to add that we have already designated Grinex and Meer cryptocurrency platforms, which are effectively the infrastructure behind rouble-backed cryptocurrency token A7A5, which you will know about. OFSI is working in partnership with the multi-agency Crypto Cash Fusion Cell, which has enabled quite a lot of intelligence-led enforcement against UK-based sanctions offenders. It goes to the point that there is a suite of bodies here—we have HMRC, OFSI and OTSI.
Joanne, is there anything you want to add to the picture that we need to understand about the use of cryptocurrency donations in sanctions evasion?
Nothing on cryptocurrency precisely.
Just to be clear, it would be OFSI with the primary responsibility for that—the Office of Financial Sanctions Implementation.
Okay. We are going to switch focus now to the occupied territories.
The Committee has looked into this, and we are very worried about the loopholes for products being produced in the occupied territories and coming on to British shores. We can focus on the goods, but we also really want to focus on the services, because that is every bit as big—if not a lot bigger. With the Chair’s permission, we will write a letter containing the concerns that we have heard from various parties, including Amnesty, about those gaps. Could you give a flavour of what you as a team are doing to close those gaps for goods and services?
I met with Amnesty as well; I had them in my office a couple of weeks ago, just before they came to see members of the Committee. To start from first principles, which is important in regard to this, the settlements are illegal and morally repulsive. That is the long-settled view of successive British Governments, and we have been clear with the Israeli Government about not only the things the Prime Minister said today on how Hamas has to surrender its arms and not be a part of the future of Gaza, but how the drive towards additional Israeli settlements is legally wrong and morally repugnant. The ICJ ruling of 2024—some of which we are still considering in quite considerable depth—says that any country would have to draw a distinction between what happens in a settlement and what happens in the rest of Israel. Part of what we are clear about is that although there are preferential tariffs for goods from the rest of Israel, they do not apply to goods from settlement postcode areas. Similarly, we do not encourage any British businesses to engage with the settlement areas in any shape or form. That includes if you make bulldozers, or if you provide financial services that would fund the building of apartment blocks—whatever it may be, we urge people to take close legal scrutiny of their decisions, because we think that they could be in profound jeopardy. I would go further and say that I actively discourage any British businesses from being engaged in those settlement areas.
If goods are identified as mislabelled, what steps are being taken to verify the origin of the goods?
I think that is one for HMRC. They are goods, so they are crossing a border, and therefore it is a question for Joanne.
Importers seeking to claim preferential tariff treatment under the UK-Israel trade and partnership agreement are required to make a legal declaration confirming that the goods were not produced in any of the settlements listed as non-eligible locations. That list of non-eligible locations is available on gov.uk. HMRC may initiate verification of origin checks on or after importation, and we do that on a risk and intelligence-led basis. In such cases, we may request further evidence from the importer or, where necessary, initiate a formal verification process with the exporting authority. Where HMRC is not satisfied that the goods meet the conditions for preferential tariff treatment, that preferential tariff treatment is refused and the goods are subject to the standard most favoured nation tariff rate.
Nobody believes that the controls on imports from the Occupied Palestinian Territories are strong enough, and when we talk to groups that work on this, they say that it is HMRC and the Foreign Office that are the problem. We do not appear to be policing those imports effectively enough. All kinds of excuses are often kicked up about the difficulty in labelling things, but it does seem that we are not approaching this with the right vigour. We have recognised the state of Palestine, yet we are permitting the economy of the state of Palestine to be undermined through the continued trade from illegal settlements. It has got to stop. Where is the plan, as part of the reconstruction of Palestine, to completely take out any risk of imports from occupied Palestinian territory?
We do not have a ban on the import of goods from settlement areas. I know there is an argument for us to have such a ban, and it is one of the things we obviously keep under constant review.
But why do we not have a ban?
Because we are keeping it under constant review.
How much more evidence do we need that the expansion, and the behaviour of settlers, is destroying the possibility of putting together a viable state of Palestine? I appreciate there is a Foreign Office lead on this, Sir Chris, but how much more evidence do we need?
I think we need to take concrete steps—obviously in accordance with international law, which is one of the things we have to bear in mind—to counter settlement expansion. The Minister for the Middle East and I are considering how we can best effect that. I do not know whether the Foreign Office wants to say anything more. I think Hamish Falconer answered a debate on some of these elements yesterday.
I don’t have anything to add to what you said.
Minister, given what you have just said, which I happen to completely agree with, about your view of the occupied territories and the illegality of those settlements, it does not sit well that we are not then acting on exactly what your sentiments are—and they are not just sentiments; they are facts—and putting that ban in place. Many other countries now are. Spain, Ireland, the Netherlands, Belgium and Slovenia are already heading down that pipe. We in the UK set an example; people look to us, and I am afraid it feels like we are sitting on the fence.
We could talk about the broader policy on Israel and Gaza at some length, though that is not my particular area of responsibility. Having looked a bit at what Ireland and Spain are trying to do—I think they are really the frontrunners in this—I would say that they are struggling to create legislation that they think will work; I will just issue a slight word of caution about that. I have heard in my office the arguments that are being made, and I hear them again today. Our aim to prevent settlement expansion is clear, and we have taken action. We are the only country, I think, that has sanctioned individual members of the Israeli Government. As the Chair has already referred to, we have taken a clear position on the recognition of Palestine, and we need to keep this whole subject under review.
Have the Government considered the merits of a ban on goods from the Occupied Palestinian Territories?
Not in the coherent way that I think you are asking me to stand up an argument around. Of course, we have heard people make an argument for that to us, and we are not deaf.
What steps can you now take, further to this Committee, in reviewing whether a ban would be possible?
I am afraid that you are not going to get any more out of me, Chair. It is not entirely my area of responsibility. We took a position in DBT that we were going to suspend some of the licences. The Foreign Office had made an adjudication that there was a real risk of Israel not abiding by international humanitarian law, so we suspended some licences under our export control system. We also suspended the FTA process with Israel for that same reason. At this moment, I am very keen to do everything I can to enable the ceasefire to hold, and for all the people of Israel and Palestine to be able to have better lives. But I am not making a commitment on behalf of the Government around what we will or will not review.
Could you tell us what steps the UK authorities currently undertake to ascertain whether an import originated in the Occupied Palestinian Territories, and therefore should not receive preferential treatment? What steps do you take today?
Those are the checks that I set out. We undertake list and intelligence-based checks, we ask for further evidence and we may require a formal verification process with the exporting authority. If we are not satisfied about the origin of those goods, we will refuse the preferential tariff treatment and charge the standard most favoured nation tariff rate, so that they do not get the advantage of the improved tariff.
It might be helpful if we wrote to you to tell you how much that happens.
That would be incredibly helpful. Obviously, we also wrote to you and other Ministers on 12 February.
I apologise—I signed it off, but it has not got to you yet.
That would be helpful to receive. Let me ask just one further follow-up. Obviously, if there has been a movement of goods from the Occupied Palestinian Territories to the United Kingdom, someone will have had to finance that. How do you go about checking who may have financed the movement of such goods, and does someone commit an offence if they undertake the financing, whether through working capital, invoice factoring or whatever else?
It is always an offence to lie to HMRC.
So you are satisfied that there are offences that should bite on those who are financing the movement of goods from the Occupied Palestinian Territories?
Anyone who lies to HMRC in a way that affects what tax, duty or tariff they pay is—
It is making an untrue declaration, and that is an offence.
I have one small point—though, ultimately, it is not small. Yes, a ceasefire has been declared, but more than 600 people have been killed in Gaza since. This is far from a ceasefire, in practice.
Point taken.
We have heard what you have said about whether, or when, the Government might consider the merits of such a ban, and we look forward to the answer to the letter that we sent on 12 February.
We have two ears and one mouth.
Moving to beneficial ownership, at the moment we have an improved situation in the UK, but it is pretty sub-satisfactory. I particularly want to ask you about property owned by a UK company that is controlled by a trust, or property owned directly by a trust, with a view to that information on beneficial ownership being accessible to the public. It is something that the Europeans are now doing, but we are not. We are doing it in every other shape and form of entity, but we are not doing it for that. Please correct me if I am wrong.
I am making a slightly confused face, because I was about to answer you in relation to beneficial ownership and the overseas territories, which I do know about, but I do not know the problems that there may be in the UK. I am afraid that this is something that I might have to write to you about—all my officials look as bewildered as I am.
The Clerks can correct me if I wrong, but as per the information that we received, if a property is owned directly by a trust, there is no searchable register of trust beneficiaries recorded through the TRS. Where available, it can be requested by interested parties, subject to a legitimate interest test, and we really do not like that bit. The applicant must demonstrate their involvement in investigating money laundering, and that the information requested will advance an investigation, which is a pretty high bar. It should just be in the public interest to have all this information available. That is with regard to property owned directly by a trust. The second one—there are only two—is property owned by a UK company controlled by a trust. This information on beneficial ownership that is accessible to the public is not currently collected at all by Companies House. If it is a beneficial ownership known to the UK Government, only the trustee of the trust needs to be made known to Companies House. There is no obligation to report the beneficiary of the trust even to the UK Government. This is just game on for bandits.
I get all of that, and I am in favour of as much transparency for the public as is possible and achievable, but I do not want to stray too far beyond my certain knowledge.
On 20 February, we received a letter back from Ministers Stephen Doughty and Blair McDougall that we, as a Committee, published last night. That was fairly helpful about the direction of travel, but we are supremely concerned that a number of Crown dependencies and overseas territories are basically slow-walking the publication of the beneficial ownership registers that they promised to create. We are concerned about what you are doing to encourage them to finish the job. Secondly, Baroness Hodge is undertaking a review on behalf of His Majesty’s Government, but I do not think we have a timetable for when that review might be concluded.
I think that both you and I were involved in this debate in 2008, 2009, 2010 and all the way through the 14 years of the other Government. It has been like pulling teeth to try to get all the overseas territories to sign up. In 2010, there was a moment when I thought we might be able to achieve it on the back of the 2008 financial problems, but we did not. Gibraltar, Montserrat and St Helena have publicly accessible registers of beneficial ownership in place. That is obviously a step forward. The Cayman Islands and the Turks and Caicos have legitimate interest access registers in place. I fully take the point that that is nowhere near good enough and we want to make sure that everybody gets to full openness. At the Joint Ministerial Council that Minster Doughty chaired in November 2025, Anguilla, Bermuda and the British Virgin Islands committed to continue with their plans to implement legitimate interest access registers. Again, we are still pressuring all of them to move towards full transparency. I do not have a timetable for Baroness Hodge’s review. She visited the BVI in 2025. You know this because it is in the letter.
Yes. We will write further to these questions.
If I may, I do not think Cayman was on that list. Cayman is one of the big three, along with the BVI and Bermuda. To give a flavour, you might have seen The Guardian today. This matters; we have $8 billion going through British island territories in, essentially, dodgy Russian stuff. We have $4.4 billion going through the BVI. The figure for the Cayman Islands is somewhere in here; I cannot find it immediately. For Bermuda, it is $3 billion, so these are big, chunky numbers. It is definitely on us to be—
I completely agree. It is one of the things that I have been committed to for a very long time. When I was a Minister in the Foreign Office, I suspended the Turks and Caicos Government because of allegations of corruption there. Oddly enough, I appointed Rob Rinder as the lawyer to deal with it. We, as a Government, are committed to do everything that we can. The powers that we have in relation to the overseas territories are relatively limited, except when they need to rely on our contingent liability provisions. I think that sometimes it is a matter of trying to persuade people, as much as anything else. That is what Minister Doughty is, I know, actively engaged in. The work that Baroness Hodge did when she was a Member of this House and does in her role now will, I hope, be able to deliver the goods.
That brings us to the conclusion of this session. Thank you very much indeed for the full and candid evidence that you have provided, and particularly for the update on the new legislation that you plan to bring forward.