Sanctions and export control | UK Regulatory Outlook September 2026

UK chancellor announces doubling of maximum OFSI fine for sanctions breaches

The chancellor of the exchequer, John Healey, has announced that the maximum monetary penalty available to the Office of Financial Sanctions Implementation (OFSI) will double, from 50% to 100% of the value of a sanctions breach.

The announcement was made at the G20 meeting of finance ministers and central Bank governors and is intended to strengthen the deterrent effect of the UK sanctions regime.

Under section 146 of the Policing and Crime Act 2017, OFSI can currently impose a penalty of up to the greater of £1,000,000 or 50% of the estimated value of the funds or economic resources involved. The change would raise the percentage limb to 100%.

NCA and NECC issue flash alert on A7 sanctions evasion network

The National Crime Agency (NCA) and the National Economic Crime Centre (NECC) have issued a flash alert on the A7 sanctions evasion network, produced with OFSI, the Foreign, Commonwealth and Development Office and financial sector partners through the Joint Money Laundering Intelligence Taskforce. It was announced on 31 August 2026 by HM Treasury, which described it as the first industry-wide alert of its kind.

The A7 network was established in 2024 by Russian-Moldovan oligarch Ilan Shor, backed by sanctioned Russian state bank PSB and state corporation VEB.RF. It claims to have settled more than $86 billion in its first year. The UK, US and EU have sanctioned A7 and its affiliates.

The alert describes how A7 moves value across borders. OFSI has identified transactions between A7 shell companies and UK-incorporated beneficiaries. The alert lists seven red flag indicators for firms to consider against existing anti-money laundering (AML) controls.

OTSI issues guidance on banknote trade sanctions

The Office of Trade Sanctions Implementation (OTSI) has issued guidance on complying with sanctions that prohibit exporting banknotes to, or for use in, Russia and Belarus under the Russia and Belarus regulations.

The prohibition covers supplying, delivering or making banknotes available to a person connected with Russia or Belarus, including sending banknotes by post, carrying them in luggage, cash withdrawals and currency exchanges.

A personal use exception applies for essential needs (accommodation, food, medical services and transport) of a traveller and immediate family, capped at £10,000 per single journey. It does not apply for commercial, investment or professional purposes.

OTSI states that it does not prescribe the level or type of due diligence companies should undertake to ensure compliance with trade sanctions. However, it reminds businesses that they should ensure their actions are compliant, particularly those in the regulated sector, such as financial institutions and money service businesses, who are subject to additional regulatory and professional standards.

Agricultural company forfeits £3.8m following NCA investigation

The National Crime Agency (NCA) announced that agricultural trading company, Enex, has agreed to forfeit £3.84 million following a civil recovery investigation by the NCA into suspected money laundering and sanctions evasion.

Enex's funds were frozen in November 2024 after it received funds from Enex Premium Trading Limited, whose owner's companies were investigated for involvement in the shipment of stolen Ukrainian grain. The NCA traced the frozen funds to Chinese bank accounts suspected of being funded by US-sanctioned companies designated for sending funds to Iran's QODS Force. Enex denies engaging in criminal activity but has agreed to forfeit the funds.

OTSI publishes 2025-2026 annual review

OTSI has published its 2025-2026 annual review. Key statistics include:

• It received 178 reports or referrals relating to potential sanctions breaches.
• 62% of reports were made by sectors to which mandatory reporting obligations apply and 6% of cases were initiated by its own investigations.
• 104 enforcement cases were closed. In 40 of these cases no breach was identified, and another 40 were referred to HM Revenue & Customs (HMRC).
• It received 50 applications related to the Russia sanctions regime and one application related to the Iran sanctions regime. Of these, 17 were granted.

Although OTSI has yet to impose any civil monetary penalties, it states that it ended 2025-26 with a "substantial number" of investigations into potential breaches at an advanced stage. OTSI will also hold sanctions workshops across the UK, which will allow businesses which may be less confident in navigating trade sanctions to learn more about sanctions compliance and receive practical support.

See the press release.

OFSI general licences and FAQs

OFSI has issued the following:

• FAQ 203, clarifying whether a relevant institution may credit interest or other earnings accruing on one frozen account into a separate frozen account held for the same designated person.

OFSI has amended the following:

• General Licences INT/2025/7895596 and INT/2025/8031092. The updated licences broaden the definition of "subsidiary" to include any non-individual person owned or controlled by Lukoil International, include a definition of entity and introduce a new reporting requirement for entities. General Licence INT/2025/7895596 now expires on 29 October 2026. General Licence INT/2025/8031092 now expires on 26 February 2027.

HMRC compound settlements for export control breaches

HM Revenue and Customs has issued a notice confirming that two UK exporters have paid compound settlement offers of £216,530.30 and £20,889.15 for breaches of export control legislation.

The settlements related to unlicensed exports of military-listed goods and related activity prohibited by The Export Control Order 2008 and contrary to The Customs and Excise Management Act 1979.

HMRC may offer a compound settlement where a breach was inadvertent or resulted from weaknesses in internal controls and was voluntarily disclosed. HMRC will not normally offer a settlement where the breach was intentional.

ECJU F680 applications move from SPIRE to LITE

From 31 July 2026, the Export Control Joint Unit requires F680 applications involving material graded "OFFICIAL-SENSITIVE" or above to be submitted through LITE rather than SPIRE.

An F680 is a form used by UK exporters to seek approval before releasing controlled military goods, technology or information to overseas recipients. Applications submitted on SPIRE after this date will be returned for resubmission through LITE. Standalone unclassified ITAR-only applications continue on SPIRE until further notice.

Read the full notice.

New OGEL for de minimis defence exports to France, Germany and Spain

The UK has issued a new open general export licence authorising the export and transfer of military goods, software and technology to France, Germany and Spain under the de minimis provisions of the Agreement on Defence Export Controls. The de minimis principle applies where the value of UK-origin items is not more than 20% of the total value of the final system into which they are incorporated.

The licence came into force on 9 September 2026. See the guidance note for registering to use this licence.