Sanctions enforcement action
Case studies and key lessons that industry can learn from enforcement actions taken by the enforcement bodies under UK sanctions regulations.
This page lists published monetary penalties, prosecution outcomes and disclosure notices imposed by:
- Office of Financial Sanctions Implementation (OFSI), responsible for civil enforcement of financial sanctions and the Oil Price Cap
- National Crime Agency (NCA), responsible for investigating and prosecuting criminal breaches of financial sanctions and transport sanctions
- Office of Trade Sanctions Implementation (OTSI), responsible for civil enforcement of trade sanctions relating to UK services and international trade where the goods and services do not cross the UK border
- HM Revenue and Customs (HMRC), responsible for the enforcement of trade sanctions within its role as the UK’s customs body
It also lists case studies, blogposts and annual reviews containing key lessons from enforcement actions in the relevant year.
OFSI enforcement actions: decisions and monetary penalties
Each enforcement notice published by OFSI has a section entitled ‘Notes on compliance’, which highlights important compliance lessons for a wide range of industry stakeholders.
OFSI enforcement actions: blogposts and annual reviews
OFSI also publishes blogposts outlining their enforcement actions and assessment process.
Svarog penalty: a lesson in information offences (8 May 2025)
HSF Moscow penalty: key lessons for industry (4 April 2025)
OFSI uses disclosure power for first time (31 August 2023)
OFSI annual reviews
OFSI’s annual reviews contain details about their enforcement actions, including disclosure notices (from 2023), naming a firm publicly but with no monetary penalty, and civil monetary penalties (from 2024).
OFSI also issues warning notices, and warning notices with a referral to the regulator. Data about these enforcement actions are recorded in all annual reviews.
NCA enforcement actions - press notices
OTSI enforcement actions: blogposts
OTSI publishes blogposts outlining key compliance and enforcement lessons.
HMRC enforcement actions: case studies
HMRC enforcement actions: enforcement notices
May 2025 - £1,160,725.67 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019. This is the largest compound settlement HMRC has concluded for a Russia sanctions offence.
NTE 2025/18: compound settlement for breaches of export control - GOV.UK
August 2024 - £58,426.45 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.
NTE 2024/29: compound settlement for breaches of Russian sanctions – August 2024 GOV.UK
September 2023 - £1,000.00 was paid relating to the export of goods in breach of The Iran (Sanctions) (Human Rights) (EU Exit) Regulations 2019.
NTE 2023/23: compound settlement - GOV.UK
August 2023 - £67,001.31 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.
NTE 2023/23: compound settlement - GOV.UK
August 2023 - £1,000,000.00 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.
NTE 2023/17: a compound settlement - GOV.UK
April 2023 - £217,012.50 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.
NTE 2023/09: Compound penalties issued - GOV.UK
September 2022 - £19,689.20 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.
NTE 2022/31: UK exporters issued compound settlements for unlicensed strategic exports - GOV.UK
August 2022 - £1,000.00 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.
NTE 2022/31: UK exporters issued compound settlements for unlicensed strategic exports - GOV.UK
Strategic Export Controls - annual reports
The Export Control Joint Unit and the Department for Business and Trade’s annual reports contain sections on compliance and enforcement.