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One Year of the Office of Trade Sanctions Implementation: What Businesses Need to Know

Steptoe & Johnson LLP | English | AcademicThink | Dec. 12, 2025 | Regulation

The Office of Trade Sanctions Implementation (OTSI) released a report covering its first year of operation from October 10, 2024, to October 9, 2025. OTSI’s mission focuses on preventing UK trade sanctions violations through compliance support and maximizing sanctions effectiveness via licensing and enforcement. The report outlines OTSI’s initial operational activities, enforcement strategies, and priorities moving forward, emphasizing the importance for businesses to review and potentially enhance their sanctions compliance programs.

During its first year, OTSI engaged extensively with businesses to raise awareness of sanctions obligations and risks, offering guidance on sanctions evasion tactics and conducting sector-specific briefings. It also developed insights into circumvention risks related to service provisions supporting sanctioned trade activities. OTSI handled 60 trade services licence applications mainly related to the Russia sanctions regime, with 43% approved either fully or partially, 11% refused, and 25% withdrawn. The average licensing decision time was around 82 working days, with plans to issue additional guidance to reduce this timeframe.

OTSI emphasized that robust enforcement underpins effective sanctions implementation. It received 146 reports of potential breaches, mostly from the financial services sector but also including reports from sectors not subject to mandatory reporting. While no civil monetary penalties have been issued yet, OTSI is actively investigating various cases and has referred several to HM Revenue and Customs for possible criminal enforcement. The agency has also prioritized international cooperation with partners across the EU, US, G7, and other jurisdictions to share intelligence and best practices.

Looking ahead to 2026, OTSI will broaden its engagement to more industry sectors, update guidance materials, and expand its trade sanctions licensing role to cover all export sanctions licensing except for strategic goods and technology overseen by the Export Control Joint Unit. Enforcement efforts will intensify with enhanced use of intelligence for proactive compliance monitoring and improved interdepartmental information sharing. Businesses operating under UK sanctions jurisdiction are advised to strengthen compliance measures in line with OTSI’s evolving approach to trade sanctions enforcement and licensing.

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