Guidance

Complying with technology transfer sanctions

Published 24 April 2025

This guidance contains information on technology transfer sanctions in the Russia (Sanctions) (EU Exit) Regulations 2019 (‘the Russia Regulations’).

It provides guidance on compliance and considers what information to include in licence applications related to the prohibitions in regulations 26, 42A, 46YA, 46Z30A, and 46Z35.

Regulations 42A, 46YA, 46Z30A, and 46Z35 have been inserted in an amendment to the Russia Regulations, the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025.

For general information regarding licensing for trade sanctions, please refer to the Russia sanctions statutory guidance.

This is a practical guide for professionals and businesses potentially affected by the Russia Regulations. It does not constitute legal advice.

If you are unclear about any aspect of the Russia Regulations, you should seek independent legal advice.

Overview

The purpose of the Russia Regulations is to encourage Russia to cease actions:

• destabilising Ukraine
• undermining or threatening the territorial integrity, sovereignty or independence of Ukraine

Sanctions on technology aim to prevent Russia, or persons connected with Russia, from acquiring information from the UK or UK persons which is required to develop, produce, and use certain goods and software subject to sanctions.

These measures are also aimed at increasing economic pressure on the Russian government and degrading its ability to fund the war.

Also see guidance on [complying with software sanctions] in the Russia Regulations.

Who the sanctions apply to

The prohibitions apply to any individual or entity in the UK and to UK persons overseas.

‘UK persons’ include UK nationals and all bodies incorporated or constituted under the law of any part of the UK. Accordingly, the sanctions apply to UK nationals and branches of UK companies operating overseas. See the full definition in Section 21 of the Sanctions and Anti-Money Laundering Act 2018.

For subsidiaries of UK companies operating overseas, which have a different legal status to branches, businesses will need to consider how the sanctions apply to UK nationals who they employ or work with.

Businesses are advised to take steps to determine whether their activities are within scope of the UK measures, including by seeking independent legal advice.

Definitions and scope

Technology

The prohibitions apply to technology related to military, dual-use, and other advanced manufactured and industrial products with value to Russia’s military-industrial and economic development.

Most technology sanctions apply to information that is required for the development, production or use of sanctioned goods and software, which may include intellectual property and trade secrets.

This information can take many forms, including:

• blueprints
• plans
• diagrams
• models
• formulae
• tables
• engineering designs and specifications
• manuals and instructions

Some technology sanctions apply to specific information as described in the UK strategic export controls lists.

Transfer of the following is prohibited by regulation 26 of the Russia Regulations:

• military technology
• dual-use technology
• critical industry technology
• aviation and space technology
• oil refining technology
• quantum computing and advanced materials technology
• defence and security technology
• maritime technology

They are defined in regulation 21 of the Russia Regulations. Where ‘technology’ is referred to in their definition it takes meaning from the Dual Use Regulation (2009). However, military and dual use technology subject to export controls take their meaning from the Export Control Order (2008).

See guidance on exporting military or dual-use technology: definitions and scope.

Transfer of the following forms of technology is prohibited by regulations 42A, 46YA, 46Z30A and 46Z35 of the Russia Regulations:

• energy related technology
• G7 dependency and further technology
• Russia’s vulnerable technology
• sectoral software and technology

These forms of technology are also defined in regulation 21 and relate to a wide range of advanced manufactured, industrial products and software listed in Schedules 3, 3E, 3I, and 3IA. Where ‘technology’ is referred to in their definition it takes meaning from paragraph 37 of Schedule 1 to the Sanctions and Anti-Money Laundering Act (2018):

“Technology” means information (including information comprised in software) that is capable of use in connection with—

• the development, production or use of any goods or software, or
• the development of, or the carrying out of, an industrial or commercial activity or an activity of any other kind whatsoever.

Transfer

‘Transfer’, as applicable to all forms of technology in the Russia Regulations, is also defined in paragraph 37 of Schedule 1 to the Sanctions and Anti-Money Laundering Act (2018):

“Transfer” in relation to any technology, means a transfer by any means (or combination of means), including oral communication and the transfer of goods on which the technology is recorded or from which it can be derived, other than the export of such goods.

The tangible transfer of technology can be in many forms. This includes information either written on physical documents or recorded on other media, such as:

• USB flash drives
• portable hard drives
• laptops
• tablets

Although technology is often transferred in an intangible form using electronic media, such as via:

• phone calls
• video conferencing
• email
• cloud storage and routing

See further guidance on technology transfer scope.

Exceptions and licences

These sanctions are subject to limited exceptions and licences.

The Russia Regulations set out exceptions to some of the sanctions prohibitions which apply within defined circumstances. An exception applies automatically and does not require you to obtain a licence issued in accordance with the Russia Regulations for a prohibited activity. Depending on the exception you may be required to report your use of it, or seek approval from a responsible officer, as detailed in the legislation.

Licences may also be issued for certain trade activities that would otherwise be prohibited by the regulations. The Department for Business and Trade (DBT) has overall responsibility for trade sanctions licensing. The Secretary of State for Business and Trade is ultimately responsible for decisions to grant or refuse a trade sanctions licence in any individual case. 

See our Statutory Guidance on the exceptions and circumstances you can get an authorisation or licence for a sanctioned activity.

Military and dual-use technologies are also subject to export controls exemptions. See guidance on export controls exemptions.

Where technology is subject to both trade sanctions and export controls, an exemption or licence under each set of legislation will need to apply. If there is an exemption or licence for the activity under one of the frameworks but not the other, it is still prohibited.

You may have a valid licence that took effect prior to the software and technology prohibitions in regulations 42A, 46YA, 46Z30A and 46Z34-46Z38 coming into force. If this licence permits an activity sanctioned by Chapters 4, 4H, 4M, 4N, 6 or 6B of the Russia Regulations, then you are permitted to transfer or make available the minimum required software and technology, or provide the minimum required direct or indirect services, to install, maintain, operate or repair goods or provide services which are specified in the licence.

This is set out in regulation 17 of the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025 (“the Transitional Provision”). Applications to renew such licences will need to include a request to transfer software and technology related to the goods or the provision of the services thereafter. 

The sanctions on ‘G7 dependency and further technology’ do not apply to information relating to goods within Chapters 6, 44, 45, 47, 48, 51, 52, 53, 54, 55, 56, 58, 59, 60, 63 or 68 of the Goods Classification Table.

The sanctions on ‘Russia’s vulnerable technology’ do not apply to information relating to goods within Chapter 44 or 68 of the Goods Classification Table.

Information in the public domain or that is basic scientific research

The technology controls in the Russia Regulations do not include information that is:

• in the public domain
• basic scientific research

Technology is in the public domain if it is freely available with no restriction other than copyright placed on its further dissemination. For example, in a book, on a website, or at an exhibition.

Information in the public domain may come in many forms including:

• general product information
• brochures
• photographs
• diagrams
• company presentations

Technology is not in the public domain:

• if it needs to be obtained from a supplier who controls the supply
• where access is restricted to certain persons, like membership of an institute or requiring passwords
• where it is subject to the Official Secrets Act, Ministry of Defence or government security classifications such as commercially confidential information
• if it has been placed in the public domain in contravention of a statutory prohibition, for example classified material, as it is unlikely to be available without further restriction upon its dissemination

The same relaxations apply to published technical papers if the content is in the public domain. However, the intention to publish a paper containing sanctioned technology does not in itself place that information in the public domain. Any collaboration or sharing of sanctioned technology overseas, such as through a peer review before publication of a technical paper or the results of research and development, would require a licence.

An example might be a product brochure taken from a publicly available website that outlines the capabilities of a piece of equipment, and this could include technology for the use of equipment. However, since the brochure is clearly in the public domain, it is not sanctioned.

Copyright restrictions such that no copyrighted work may be copied, published, disseminated, displayed, performed, or played without permission of the copyright holder, except in accordance with fair use or licensed agreement, does not necessarily mean that technology is not in the public domain.

For commercial reasons, exporters are unlikely to place sanctioned technology onto freely available sites, for access by suppliers, customers or indeed competitors.

Technology which is basic scientific research is not sanctioned. The exchange of research material between an academic based in the UK, for example, and another overseas would not be sanctioned if it were basic scientific research.

Basic scientific research might include, for example, the study of the low temperature electrical resistance of metals.

Applying for a licence

DBT has 3 licensing bodies responsible for administering trade sanctions licences on behalf of the Secretary of State. Which body you need to apply through is dependent on the activity you want to carry out.

If you are carrying out an activity that falls under the remit of more than one licensing body, you will need submit separate licence applications for each one.  It is your responsibility to ensure you have all the required permissions before exporting goods or transferring technology.

DBT has produced guidance where you can check which trade licence you need. This will guide you to the application page for each type.

Reporting a suspected breach of trade sanctions

If you think you may have breached technology transfer sanctions when crossing UK borders, including ancillary services relating to the transfer of that technology, you should make a voluntary disclosure to His Majesty’s Revenue and Customs (HMRC) at exports.strategic@hmrc.gov.uk

To report a suspected breach relating to technology by a UK entity or by UK persons within the UK, including any ancillary services to the transfer of that technology, contact HMRC using report a breach to HMRC. 

To report a suspected breach relating to technology by a UK entity or by UK persons outside of the UK, including any ancillary services to the movement of that technology, contact the Office of Trade Sanctions Implementation (OTSI) using the report a breach tool.

Read our data privacy notice for allegations of breach of services sanctions under The Russia (Sanctions) (EU Exit) Regulations 2019.