On 10 February, the Office of Trade Sanctions Implementation (OTSI), the Export Control Joint Unit and the Department for Business and Trade updated their Guidance titled How to apply for a trade sanctions licence.
There are currently three bodies within the UK Government responsible for licensing activities that are otherwise prohibited under UK trade sanctions.
The OTSI is responsible for licensing which involves standalone services, including professional and business services (trade services licence). An OTSI licence is required if you are a sole trader that provides services prohibited under sanctions or if your company is planning to provide services which are prohibited under UK sanctions regimes. You may be required to apply for an OTSI licence even if you are a non-UK company but have UK employees that are engaged in providing services that are banned under sanctions.
The Imports Controls and Sanctions team of the Department for Business and Trade are responsible for issuing licences for the import of goods and associated activities (import licence). A licence is required if you are looking to import sanctioned goods, like Russian caviar or Russian steel. A licence application submitted after your goods reach the UK border will be refused. Furthermore, you may be criminally liable for importing sanctioned goods without a licence.
The Export Control Joint Unit is in charge of licensing the export of goods, software and technology from the UK (strategic export licence). Thus, if you or your company are considering exporting luxury goods, including porcelain, carpets or works of art to Russia, an application for a licence is required. A licence is also necessary for export of military and dual-use items which are on the UK’s strategic export control list.
The list of examples which require trade services or import and strategic export licences is not exhaustive and is subject to changes. The UK Licensing regime is complex and is rapidly evolving, and we strongly recommend seeking legal advice if you are uncertain whether your or your company’s operations require any of the abovementioned licences.
Updated: 11 February 2025
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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.
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