New sanctions-related end-use control in the United Kingdom

The United Kingdom’s Department for Business Trade (DBT) published, on 22 April, guidance for undertakings on sanctions end-use controls in the field of export control. This guidance does not have binding normative force. It accompanies the adoption of the Sanctions Regulations^[1] of 20 April 2026 entering into force on 13 May 2026 (2026 No. 443 The Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026).

The purpose of sanctions end-use controls of goods is to combat the circumvention of trade sanctions. Circumvention risks are deemed high for exporters shipping to third countries such as Indonesia, Thailand, Turkey, and Kyrgyzstan.

1.Sanctions-related end-use control (SEUC: “Sanctions End-Use Controls”)

The new control implemented by the British authorities henceforth requires a licence for exports to non?sanctioned third countries where the government has informed the exporter of the risk of circumvention of sanctions.

Prior to the entry into force of this mechanism, HMRC (His Majesty’s Revenue and Customs)  and the Department for Business and Trade confined themselves, where applicable, to informing the exporter of the identified risks, without being able to impose any obligation. It was for the exporter, at its sole discretion, to decide whether or not to proceed with the export.

Now, the requirement for a new licence enables the British government to assess the potential risk and, where necessary, to prevent exports where the risk of sanctions circumvention is deemed to be high.

2.The goods concerned

Controls are based on the current prohibitions on making restricted goods and technologies available to a sanctioned destination.[2] These prohibitions are expressly set out in the sanctions lists[3] published by the United Kingdom and in “The Export Control Order 2008” and the “Export Control Act 2002[4]”.

The end-use control applies extensively, beyond arms embargoes (for which the military end-use control already applies). The control applies to goods and related technologies that are sanctioned under the sanctions regimes applicable to: the Republic of Belarus, the Democratic People’s Republic of Korea, Iran, Libya, Myanmar, Russia and the territories of Ukraine not controlled by the government of Ukraine, Somalia, Syria, Venezuela and Zimbabwe.

3.Who is required to submit an application for an SEUC licence?

Phase 1, (i) the government “informs” the exporter that their flows present a risk of being diverted to a sanctioned person. This information shall be issued by the National Clearance Centre (HMRC) or by contacting OTSI (Office of Trade Sanctions Implementation)^[5]. Anticipated SEUC licence applications shall not be received by OTSI; the exporter shall be required to await notification from the government.

Phase 2, (ii) the exporter must submit an application for a SEUC licence on OTSI’s online platform^[6]. The OTSI guidance has been updated for this purpose^[7].

Since 27 April, the OTSI has been responsible for issuing export licences for sanctioned goods (and associated ancillary services) intended for export to sanctioned destinations, via the SPIRE system of the Department for Business and Trade.^[8] Conversely, the Export Control Joint Unit (ECJU) retains jurisdiction to issue licences for dual?use or military goods, software and technology that are controlled abroad (Open General Export Licences “OGELs”).

Phase 3, (iii) the OTSI shall grant or refuse the SEUC licence, thereby preventing export to the identified end?user or along the identified route. The assessment of licence applications by OTSI generally requires a minimum of 6 months. No specific time limit has been provided to date in respect of SEUC licences. Export licences are issued by e?mail.

In the event of a breach of the prohibition arising from the licence refusal, the exporter is, in particular, exposed to monetary penalties, to the refusal or revocation of existing and future export licences, and to being identified as an entity infringing sanctions.

[1] https://www.legislation.gov.uk/uksi/2026/443/made/data.pdf

[2] See for example, the prohibition on exports to Iran of tropospheric scatter communication equipment using analogue or digital modulation techniques and components specially designed therefor (PL9005, Export Control Order 2008: https://www.legislation.gov.uk/uksi/2008/3231/data.pdf)

[3] https://www.gov.uk/government/publications/the-uk-sanctions-list  https://www.gov.uk/guidance/trade-sanctions-arms-embargoes-and-other-trade-restrictions

[4] https://www.legislation.gov.uk/ukpga/2002/28/data.pdf

[5] https://www.gov.uk/government/organisations/office-of-trade-sanctions-implementation/about

[6] https://signin.account.gov.uk/sign-in-or-create

[7] https://www.gov.uk/guidance/apply-for-a-licence-to-carry-out-sanctioned-trade-through-otsi

[8] https://otsi.blog.gov.uk/2026/04/09/expanding-otsis-licensing-remit/

SOURCES:

Guidance published on 22^nd April 2026 by the Dept of Business & Trade / Office of Trade / sanctions implementation : Sanctions end-use controls : guidance for businesseshttps://www.gov.uk/government/publications/sanctions-end-use-controls-guidance-for-businesses

The Sanctions (“EU Exit”) (Miscellaneous Amendments) Regulations 2026 –> coming into force 13^th May 2026

https://www.legislation.gov.uk/uksi/2026/443/made/data.pdf