Corporate report

Agreed compound settlements for strategic export and sanction offences

Published 8 September 2026

The current list contains compound settlements which have been agreed from 13 August 2026 to date. The businesses agreed to pay the ‘compound settlements’ as an alternative to criminal prosecution.

We typically publish this information after the agreement has been signed and paid in full.

Please be aware that the published person may have changed their behaviour.

Illumina Cambridge Limited (published 8 September 2026)

1. Overview 

Illumina Cambridge Limited (Illumina) has paid HM Revenue and Customs (HMRC) a compound settlement of £7,438,840.13 for offences under The Russia (Sanctions) (EU Exit) Regulations 2019 (the Russia Regulations). 

Between July 2022 and January 2023 Illumina breached regulation 25(1) through their involvement in the supply of sanctioned goods from one overseas company within their corporate group to another overseas company within their corporate group for export to Russia and other destinations. 

This case was brought to HMRC’s attention following a voluntary disclosure by Illumina, who have fully cooperated with HMRC’s investigation and undertaken remedial actions, including ceasing all business involving Russia. 

The case highlights how sanctions breaches can occur when UK businesses are involved in supply chains that result in sanctioned goods being supplied indirectly to Russia (or other countries subject to trade sanctions), even when no goods have been exported from the UK. It also shows the importance of checking UK sanctions even, if the goods are not sanctioned in the place of origin or of export. 

Businesses involved in the supply of sanctioned goods to entities in third countries are encouraged to read the guidance from the Department for Business, Innovation, Science and Trade on Countering Russian sanctions evasion. 

2. Compound settlements criteria 

Compound settlements may be offered where an exporter has both: 

• committed a breach that was inadvertent or due to weaknesses in internal controls – HMRC will not normally offer a compound settlement where an exporter intended to breach the controls 

• voluntarily told HMRC about sanctions or export control breaches 

3. Other information 

In May 2026, the government introduced Sanctions End-Use Controls (SEUC). SEUC constitute a new licensing requirement for export to a non-sanctioned third country where the exporter has been informed by the government that there is a risk of ultimate diversion of the goods or related technology, via that route, to a sanctioned destination. Guidance on SEUC is available on GOV.UK. 

Airbus Operations Limited (published 30 July 2026)

Airbus Operations Limited (AOL) has paid more than £6.4 million to HM Revenue and Customs (HMRC) after admitting multiple breaches of Strategic Export Controls.  

The payment represents the highest compound settlement ever reached by HMRC for strategic export offences. 

AOL announced the breach in its quarterly earnings notes and details have been published on GOV.UK.

On multiple occasions the company failed to keep accurate records of transfers of controlled technology as per the conditions of three of their Open General Export Licences (OGELs).

AOL self-reported the breaches to HMRC and fully cooperated with the investigation.

The breaches made by AOL included:

• Article 29(2)(a-g) on multiple occasions for failing to keep accurate records of transfers of controlled technology as per the conditions of three of their OGELs
• Article 29(3) on multiple occasions for failing to keep registers in relation to their OGELs
• Article 29(2)(i) on multiple occasions for failing to keep accurate records contrary to the conditions of one of their OGELs
• Standard Individual Export Licence – on one occasion relating to a failure of licence conditions

Two anonymous cases (published 27 July 2026)

In June 2026, 2 UK exporters paid compound settlement offers of £216,530.30 and £20,889.15 to HM Revenue and Customs (HMRC).

The settlements relate 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.

Petrofac Facilities Management Limited (published 29 June 2026)

Petrofac Facilities Management Limited (PFML) paid a £569,157 compound settlement and has become the first company to be publicly named by HMRC for accepting such a penalty.

The breaches by PFML occurred in 2022 and 2023 while the company was winding down its Russian operations. The company supplied sanctioned industrial goods to individuals connected to Russia and provided technical assistance relating to those goods. 

PFML self-reported the breaches to HMRC and fully cooperated with the investigation.

Naming the company marks a shift in how HMRC handles compound settlements in relation to strategic exports and sanctions.