Sanctions and export control | UK Regulatory Outlook April 2026

OFSI publishes 2026-2029 strategy 

The Office of Financial Sanctions Implementation (OFSI) has published its strategy for 2026-2029, which details how it plans to ensure UK financial sanctions remain effective, make expectations clearer and invest in improvements to tools to target the highest risk activity as it enters its second decade of operation. 

The strategy summarises OFSI's activities between 2021 and 2026. During this period, it progressed over 1,400 enforcement cases, resulting in 18 public enforcement decisions and over £22 million in monetary penalties. Over 100 general licences were also issued, with the aim of supporting legitimate activity.

Under the "Promote, Enable and Change" framework: 

• Promote – OFSI will make sanctions rules and expectations clearer. This includes working with international partners to deliver joint guidance aimed at tackling sanctions circumvention.
• Enable – OFSI will aim to remove friction for legitimate activity such as through providing practical guidance on complex scenarios, and using digital by default engagement methods such as online services, reporting and forms. The key performance indicator (KPI) is that 50% of licensing cases closed will be completed within six months.
• Respond – OFSI will act quickly and proportionately on breaches, using the enforcement "toolkit" (such as settlements and fixed monetary penalties) to deter non-compliance and circumvention. The KPI is for 90% of new enforcement investigations to be submitted for decision within 18 months of commencement.
• Change – OFSI will embed lasting improvements by learning from cases and engagement, driving sustained compliance cultures in firms and sectors. This includes ensuring all new and updated sanctions enable practical implementation. The KPI is that 90% of new enforcement investigations will be submitted for decision within 18 months of commencement of investigation.

OFSI committed to monitoring progress under the strategy against the KPIs, with the aim of reporting against them in its annual reviews, starting with the next publication this autumn. See the related blog post. 

UK introduces new end-user licensing requirements to sanctions regimes 

On 22 April 2026, the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 were laid before Parliament alongside the explanatory memorandum. The regulations will come into force on 13 May 2026 and make the following changes to the UK's sanctions regulations: 

• End-user controls – the regulations introduce end-user controls which will prohibit export of sanctioned goods once the exporter has been notified of the risk of a specific export or transfer of technology being diverted to a sanctioned destination or person. Exporters who wish to proceed will need to obtain an export licence.
• Relevant firms reporting thresholds changed from euros to pounds – the definitions of high-value dealers and art market participants within the relevant firms regulations will be updated so that monetary thresholds are expressed in pounds sterling (£) rather than euros (€). The €10,000 threshold will be replaced with a £10,000 threshold.
• Electronic notices for licences – the regulations will confirm that OFSI and other relevant authorities may issue licence notices electronically without requiring prior consent.
• HM Treasury debt exception – the regulations clarify that the exception for Treasury debt applies to all transfers of funds across the entire payment chain, including intermediaries.
• Updates to the prior obligations licensing ground – the regulations broaden the prior obligations licensing ground, granting OFSI greater flexibility to license legitimate pre-designation obligations where appropriate. 

OTSI publishes update on expanded licensing remit 

As previously reported, the Office of Trade Sanctions Implementation (OTSI) will assume responsibility for licensing the export of sanctioned goods and the provision of associated ancillary services from 27 April 2026. 

It has published a blog post explaining the changes and clarifying that the process for applying for an export sanctions licence remains unchanged, with applications continuing to be submitted through the SPIRE service. 

OTSI will be responsible for processing licence applications relating to the export of sanctioned goods and associated ancillary services. Applications involving goods and ancillary services that are subject to both sanctions and strategic export controls will remain the responsibility of the Export Control Joint Unit (ECJU). The guidance pages on application processes have been updated accordingly to reflect the changes to OTSI's licensing responsibilities.

OTSI publishes guidance on sanctions end-use controls 

OTSI has issued guidance on sanctions end-use controls, which aims to help businesses understand the new licensing requirements for sanctions end-use controls introduced in relevant sanctions legislation containing export prohibitions, and to support exporters to third countries where there is a high risk of diversion of goods and related technology to a sanctioned destination or person. 

This measure applies only to goods or technology related to the export of those goods that are not otherwise subject to strategic export controls. The guidance details the goods covered by sanctions end-use controls, the steps to take when notified by the Department for Business and Trade that an export is at risk of sanctions circumvention, best practice around compliance, record keeping and risk awareness. 

OFSI fines Irish-incorporated company £390,000 for breach of Russia sanctions  

OFSI announced it has issued a £390,000 monetary penalty against an Irish-incorporated entity, for breaches of the Russia (Sanctions) (EU Exit) Regulations 2019. 

The breach related to two payments totalling £635,618.75 to Okko LLC, a company owned by a designated person. The company's failure to cancel these payment instructions, leading to the release of funds to Okko LLC, amounted to conduct in the UK. 

The case was assessed to be "serious". Aggravating factors included the high collective value of the payments and the company's reliance on third-party providers for ownership and control data. OFSI stresses that the company remains ultimately responsible for ensuring that it is compliant with financial sanctions. 

This is the first penalty OFSI has imposed on a non-UK company for taking action in the UK, and the first OFSI case resolved under the new enforcement scheme. As such, OFSI applied a 35% discount to reflect the company's voluntary disclosure and settlement of this case.

OFSI director publishes blog post on OFSI’s 10th anniversary 

The director of OFSI, Giles Thomson, has posted a blog post commemorating its tenth anniversary. Some of his reflections include the expansion of the sanctions regime, demonstrated by the figures in OFSI’s 2024-2025 annual report which saw £37 billion in assets reported to OFSI as frozen across all sanctions regimes.

Mr Thomson also notes the evolution of OFSI's enforcement, which is "increasingly targeted, intelligence-led and proactive", with use of a range of tools including guidance, warning letters, public disclosure and monetary penalties to promote compliance and deter breaches. Looking ahead, he highlights that OFSI's focus as it enters its second decade is firmly forward-looking, as captured in the three-year strategy (see above). He states that OFSI will convene with partners from across sectors at the OFSI10 Conference in April to reflect on its journey to date and consider future priorities. 

OFSI general licences and FAQs  

OFSI has amended the following: 

• General Licence INT/2022/2300292, which allows for payments to utility companies for gas and electricity by UK designated persons who own or rent UK properties, has been amended to permit all forms of utility payment, including cash. It came into effect on 17 November 2022 and is of indefinite duration.
• General Licence INT/2022/2009156, which allows designated individuals or entities to make payments to UK insurers for insurance premiums and broker commissions relating to insurance cover for UK properties, has been amended to allow insurance premium finance repayments to be made to UK intermediaries rather than insurers or brokers. It came into effect on 22 July 2022 and is of indefinite duration.
• General Licence INT/2026/8893924, which allows for the winding down of insurance policies written by Maritime Mutual entities and their subsidiaries before their designation, has been extended. It came into effect on 24 February 2026 and now expires on 8 July 2026.
• General Licence INT/2023/2824812, which allows for certain transactions related to bond amendments and restructurings for non-designated persons, has been extended. It came into effect on 28 March 2023 and now expires on 26 March 2028. 

ECJU publishes general licences and notices to exporters  

The ECJU has published the following guidance for exporters: 

• Submitting export licence applications, to support exporters in preparing and submitting export licence applications under Articles 1, 2 and 3 of the Agreement on Defence Export Controls. 

The ECJU has published the following notices to exporters: 

• NTE 2026/12, which advises of changes to the team responsible for trade sanctions licensing responsibilities.
• NTE 2026/11, which advises exporters of the transitioning the MOD security approval form 680 (F680) away from SPIRE.
• NTE 2026/09:which advises exporters of changes to the process for submitting amendment requests for open individual export licences (OIELs) and the way they are assessed. 

The ECJU has amended the following general licences: 

• Open general licence (AUKUS nations), which allows the export of dual-use items or military goods, software or technology and the trade of military goods to, between and among the UK, Australia and the USA, has been amended to permit the export of goods, software or technology to Australian, US or UK armed forces, including when deployed.
• General trade licence Russia sanctions: sectoral software and technology, which allows the transfer, making available of and provision of ancillary services in relation to business enterprise software and technology under certain conditions. The updated licence replaces the previous version published in July 2025.