Sanctions and export control | UK Regulatory Outlook May 2026

The Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 in force from 13 May 2026 

The Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 (SI 2026/443), which came into force on 13 May 2026, amend the UK sanctions framework across 11 regimes, with Russia circumvention being a focus. 

Key changes include: 

• Sanctions end-use controls (SEUCs): A new licensing requirement for exporters where the UK government determines there is a high risk of goods being diverted to a sanctioned territory. Exporters will be formally notified by the Department of Business and Trade (DBT) or the Office of Trade Sanctions Implementation (OTSI) before the requirement is triggered; OTSI is not currently accepting advance SEUC licence applications. 
• Prior obligations licensing ground: Broadened so that it applies to a wider range of scenarios across UK autonomous sanctions regimes (see OFSI FAQ 185 below). 
• Reporting threshold: The €10,000 reporting threshold for high-value dealers has been replaced with a £10,000 threshold. 
• HM Treasury debt exception: Clarified to apply across the full payment chain. 
• Electronic licensing notices: Confirmed that licensing notices may be issued electronically without prior consent. 

Sanctions end-use controls: guidance for businesses (in force 13 May) 

OTSI published official guidance for businesses on the new SEUC regime, which applied from 13 May 2026. It confirms that exporters will be formally informed by DBT or OTSI if their goods are assessed to be at risk of diversion triggering the licensing requirement and that OTSI is not currently accepting advance SEUC licence applications. Exporters should therefore wait to be notified before applying. The guidance cross-references the government's Russia evasion guidance. 

ECJU Notice to Exporters 2026/13: OGEL and GEA declarations on CDS 

The Export Control Joint Unit (ECJU) has published Notice to Exporters 2026/13, informing exporters of an upcoming requirement to enter their unique Open General Export Licence (OGEL) or General Export Authorisation (GEA) licence reference number into box 44 of the UK's Customs Declarations System (CDS) for all tangible exports.  

Currently, only a limited number of OGELs carry this condition, but the ECJU will be updating all relevant OGELs in the coming months to bring them into line with Standard Individual Export Licences (SIELs) and Open Individual Export Licences (OIELs).  

Once the condition is added to a given OGEL, failure to include the correct reference on CDS could lead to HMRC enforcement.  

Where exporters use freight forwarders to make declarations on their behalf, they must ensure the correct licence reference is provided. An incorrect declaration could lead to a criminal offence under section 167 of the Customs and Excise Management Act 1979. Exporters are being encouraged to begin including OGEL/GEA references on CDS now as good practice ahead of the formal rollout. 

Criminal enforcement: NCA charges for breach of Russia sanctions 

The National Crime Agency has brought charges against an individual for breach of the Russia financial sanctions regime, one of the first of its kind. 

The defendant faces two charges:  

• dealing with a £200,000 transfer in contravention of Regulation 11 of the Russia (Sanctions) (EU Exit) Regulations 2019 whilst himself a designated person; and  
• transferring £100,000 he knew or suspected was criminal proceeds, contrary to section 327(1) of the Proceeds of Crime Act 2002.  

The first court appearance was at Westminster Magistrates' Court on 15 May 2026 (reporting restrictions apply). 

OFSI FAQ update: prior obligations licensing ground  

OFSI added FAQ 185 to address the changes to the prior obligations licensing ground made by The Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026, in force from 13 May 2026.  

The key changes: 

• It is no longer a condition that the funds or economic resources used to satisfy a prior obligation must themselves be frozen under UK sanctions. 
• For designated persons (DPs) under UK autonomous sanctions regimes, the limitations on whose funds or economic resources may be used have been removed. 
• For UN DPs where the prior obligations ground applies, the limitations have been amended to allow the prior obligations of owned or controlled entities to be satisfied using the funds or economic resources of the DP, or of other owned or controlled entities and vice versa. 

OFSI retains discretion on decision making even where conditions are met. 

New Russia designations (5 May 2026) 

The UK announced 35 new designations for individuals and entities involved in Russia's drone production supply chains and networks exploiting vulnerable migrants. The measures include designations linked to Russia's Alabuga Start drone production programme and third-country suppliers in Thailand and China.  

The 5 May tranche also marks the first use of the GIMTiPS (Global Irregular Migration and Trafficking in Persons) sanctions regime to tackle human trafficking and the instrumentalisation of migration as a tool of destabilisation. See the full designation list and sanctions notice. 

New Russia designations (11 May 2026) 

The UK designated a further 85 individuals and entities in two distinct tranches: 29 designations targeting those involved in the forced deportation, indoctrination and militarisation of Ukrainian children, and 56 designations targeting individuals responsible for Kremlin-backed information warfare campaigns. See the full designation list and sanctions notice. 

The 5 and 11 May 2026 tranches added 120 individuals and entities to the UK sanctions list this month alone.