HMRC concludes a compound settlement for breaches of Russian sanctions

Jul 11 2025

Sanctions Updates

On 8 July, HM Revenue and Customs (HMRC) published their Notice to Exporters: NTE 2025/18 as relate to the compound settlement of £1,160,725.67 with the UK exporter that made goods available to Russia in violation of the Russia (Sanctions) (EU Exit) Regulations 2019.

The compound settlement, which was paid to HMRC in May 2025, is the largest sum paid out for a breach of Russia sanctions offence to date.

The HMRC did not name the company that committed the sanctions breach, which is in line with their approach to disclosure of names on a case-by-case basis, as outlined in their February response to the Treasury Select Committee of the House of Commons. In situations where a business has taken steps to bring themselves in compliance, HMRC normally would not “name them if doing so could have a disproportionate impact on their reputation, and ability to trade domestically and internationally”.

The latest compound settlement shows the increasing enforcement of sanctions in the UK. It is recommended that businesses regularly assess their risks and re-evaluate existing sanctions programmes and policies to avoid hefty penalties and criminal responsibilities.

Updated: 11 July 2025

How Gherson can assist

The Gherson team have years of experience advising on compliance matters, including sanctions. We regularly advise clients on sanctions laws and can assist companies develop policies and systems aimed at prevention of sanctions risks.

If you have any questions arising from this blog, please do not hesitate to contact us for advice, send us an e-mail or, alternatively, follow us on XFacebookInstagram or LinkedIn to stay-up-to-date.

The information in this blog is for general information purposes only and does not purport to be comprehensive or to provide legal advice. Whilst every effort is made to ensure the information and law is current as of the date of publication it should be stressed that, due to the passage of time, this does not necessarily reflect the present legal position. Gherson accepts no responsibility for loss which may arise from accessing or reliance on information contained in this blog. For formal advice on the current law please do not hesitate to contact Gherson. Legal advice is only provided pursuant to a written agreement, identified as such, and signed by the client and by or on behalf of Gherson.

©Gherson 2025

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