Policy paper

UK Government's strategic approach to sanctions enforcement

Published 10 March 2026

Introduction

1. Robust enforcement of UK sanctions is a priority for this government, without which sanctions become ineffective, undermining both domestic and global security. A coherent government-wide approach is vital to ensuring that our sanctions have the intended impact.

2. In May 2025, the government published a cross-government review of sanctions implementation and enforcement (“the review”). The review focused on improving and facilitating compliance, increasing the deterrent effect of enforcement and strengthening the cross-government toolkit. It included a commitment to publish a cross-government strategy on enforcement to help industry understand the range of non-compliance and possible enforcement consequences.

Key objectives

3. This document aims to improve industry’s understanding of sanctions enforcement and encourage compliance, making clear the wide-ranging consequences of non-compliance, especially for those who deliberately seek to evade UK sanctions.

4. This document sets out the government’s strategic approach to enforcing UK sanctions. It brings together information on civil and criminal enforcement of sanctions across government departments and agencies. It outlines our expectation of the relationship between compliance and enforcement, defines government roles and responsibilities, sets out our overarching enforcement principles, and details the range of enforcement tools available, along with the mitigating and aggravating factors taken into account in enforcement decisions.

Why compliance and enforcement matter

5. Sanctions are a vital foreign policy and national security tool, used to deter and disrupt threats and malign behaviour, and to demonstrate our values. The UK uses sanctions to isolate, restrict or change the behaviour of the actors targeted, and to send a wider message.

6. Robust compliance by UK industry is critical to the implementation and impact of UK sanctions, and the UK has a strong compliance culture. Where compliance or deterrence is effective, or where enforcement action has successfully disrupted activity, there will be fewer consequent enforcement actions.

7. Our partnership with UK industry and the role of engagement, guidance and licensing is vital to compliance. The government understands that businesses want simplicity, clarity, transparency and the cost of compliance to be proportionate to their size and exposure to sanctions risks. We provide accessible guidance to help users understand and implement sanctions. We are committed to proactively engaging with industry to enhance understanding of UK sanctions and to address specific challenges. This approach gives businesses confidence and supports a regulatory environment that is conducive to economic growth.

8. To drive compliance, maximise the deterrent effect of sanctions and give them bite, there must be clear, appropriate and proportionate consequences for those who do not comply. We use our toughest measures in response to the most serious and deliberate breaches. Enforcement changes behaviour, deters breaches, and protects the UK’s sanctions regimes and the UK economy.

Government roles and responsibilities 

9. The Foreign, Commonwealth and Development Office (FCDO) is responsible for the UK’s overall foreign policy, including definition of high-level policy objectives, sanctions regimes design and strategy ^{[footnote 1]}. It is also responsible for designations, which are decisions to apply certain sanctions measures to specific individuals or entities, and for the specification of ships. The Office of Financial Sanctions Implementation (OFSI) leads on designations under the UK’s domestic counter-terrorism sanctions regime.

10. A range of departments, agencies and regulators are responsible for the effective enforcement of UK sanctions and work closely to ensure a joined-up approach. The division of responsibilities and cross-departmental working includes referral processes for criminal enforcement.

Sanctions enforcement: Responsibilities at a glance

Type of Sanction	Civil Responsibility	Criminal Responsibility[footnote 2]
Financial	Office of Financial Sanctions Implementation	National Crime Agency
Oil Price Cap	Office of Financial Sanctions Implementation	HM Revenue and Customs National Crime Agency
Trade[footnote 3]	Office of Trade Sanctions Implementation	HM Revenue and Customs
Transport	Department for Transport	National Crime Agency
Internet Services	The Office of Communications (OFCOM)	HM Revenue and Customs
Immigration	Home Office	Home Office
Director Disqualification	Insolvency Service	Insolvency Service

Who does what: Sanctions enforcement explained

The following list sets out roles and responsibilities for sanctions enforcement^{[footnote 4]}:

• The Office of Financial Sanctions Implementation (OFSI) – Part of HM Treasury, OFSI has civil enforcement responsibility for financial sanctions and the Oil Price Cap. Cases may be referred for criminal investigation to law enforcement partners including the National Crime Agency and His Majesty’s Revenue & Customs (HMRC).
• The National Crime Agency (NCA) – Leads on criminal enforcement of financial and transport sanctions breaches. Its Serious Organised Crime and State Threat Unit (the Combatting Kleptocracy Cell) targets corrupt elites, proxies and enablers linked to serious organised crime and hostile states, and supports cross-government sanctions enforcement.
• The Office of Trade Sanctions Implementation (OTSI) – Part of the Department for Business and Trade (DBT), OTSI leads on the civil enforcement of sanctioned services, as well as trade in sanctioned goods, technologies and services outside the UK, where a UK person is involved. OTSI can refer cases to HMRC to consider criminal investigation.
• HM Revenue and Customs (HMRC) – Working in close partnership with Border Force, HMRC is responsible for the enforcement of trade sanctions within its role as the UK customs authority. This applies to goods that cross the UK border and strategic goods and technology (as well as services ancillary to those movements). It also criminally investigates relevant breaches referred by other agencies.
• The Department for Transport (DfT) – Has civil enforcement responsibility for transport sanctions and may refer cases to the NCA for criminal investigation.
• The Office of Communications (OFCOM) – Has responsibility (as an independent regulator) for the civil enforcement of internet services breaches and can refer cases to HMRC for criminal enforcement action.
• The Home Office – Is responsible for enforcing immigration sanctions, also known as travel bans.
• The Insolvency Service – An executive agency of DBT, the Insolvency Service is responsible for investigating breaches of director disqualification sanctions and licensing offences, with powers to prosecute.
• The Serious Fraud Office (SFO) – May investigate and consider prosecution of sanctions-related fraud cases.
• The police (including Counter-terrorism and regional police forces) – May receive referrals for criminal investigation and prosecution.

Roles of independent regulators:

• The Financial Conduct Authority – Ensures that the firms it supervises have adequate systems and controls to comply with the UK’s sanctions regimes. They may refer suspected cases of sanctions breaches to OFSI or OTSI.
• The Solicitors Regulation Authority – Supports the implementation of the UK’s financial and trade sanctions regimes by setting clear expectations for firms to conduct thorough due diligence, screen clients and counterparties against sanctions lists, and report any suspected breaches or designated persons. It may take enforcement action where firms fail to comply.
• Office for Professional Body Anti-Money Laundering Supervision – Promotes and supports compliance with the UK’s sanctions regimes across the accountancy and legal sectors.
• Other regulators and professional bodies – Ensure regulated persons are meeting their professional obligations, and have systems in place to detect and/or prevent financial crime within their sectors and refer suspected breaches of sanctions to the relevant authorities.

Licensing and reporting suspected breaches

11. Licensing is a critical part of the UK’s sanctions framework. It provides a legal route for activities that would otherwise be prohibited under sanctions regulations, helping businesses and individuals remain compliant.

12. Prompt reporting of suspected breaches also protects the integrity of sanctions and assists government and law enforcement agencies in tackling serious crime. Anyone can report a suspected breach. The sanctions pages on GOV.UK can guide those looking to report a suspected breach to the right reporting body: How to report a suspected breach of sanctions

13. Sanctions regulations also impose reporting obligations on certain types of firms. These obligations are set out in guidance from OFSI, OTSI and DfT. Relevant guidance is available on GOV.UK:

• Section 5 of the guidance from the Office of Financial Sanctions Implementation
  
• Guidance on reporting obligations from the Office of Trade Sanctions Implementation
  
• Section 9 of the guidance from the Department for Transport

14. Annex 1 provides a table summarising the licensing and reporting framework, including who to apply and report to.

Enforcement: Civil and criminal

15. When compliance falls short, we respond by tackling breaches effectively. We do this to change behaviour, directly preventing future non-compliance by the individual or entity, and more widely by others through the deterrent impact of enforcement action.

16. Sanctions enforcement investigations and action can be either civil or criminal, the range of tools for both are set out below. Effective enforcement involves a balance between civil penalties, criminal prosecutions and other disruptions, such as asset freezes and forfeiture. Mitigating and aggravating factors will be considered in determining the type of enforcement response and the value of penalties imposed.

17. Criminal investigation and action are used for the most serious or deliberate cases and where the conduct involved is such that criminal enforcement is most appropriate. It will not always be the best approach, and in some cases civil enforcement can be equally effective in achieving future compliance and deterrence. That is why it is important to have a broad and effective enforcement toolkit of civil and criminal powers.

18. Investigation and enforcement action is triggered when there is a breach of UK sanctions by an individual or entity. Breaches can include:

• making funds or services available to a designated person
• dealing with frozen assets
• importing or exporting sanctioned goods, and providing services ancillary to those movements
• providing goods, technology, or related services indirectly to a sanctioned person, entity or for use in a sanctioned country
• providing sanctioned services
• circumvention (for example, facilitating a prohibited transaction)
• permitting prohibited vessels or aircraft to enter a UK port or land at a UK airport
• breaching licence conditions
• failing to comply with reporting or record-keeping obligations
• failing to comply with a request for information

Enforcement principles

19. The government’s approach to sanctions enforcement is guided by 4 principles:

i. Driving compliance – we promote sanctions compliance through guidance and engagement.

ii. Proportionality and fairness – enforcement action should be proportionate to the nature and impact of the breach, and consistent with the purpose of UK sanctions. This will include:

• a case-by-case assessment – evaluating each suspected breach individually, considering the specific facts, context, and applicable regulations.
  
• a balanced consideration of mitigating and aggravating factors when deciding on enforcement outcomes – such as voluntary disclosure, cooperation, due diligence and controls in place, intent, severity and harm caused.
  

iii. Transparency – we publish significant enforcement outcomes and key lessons for industry where appropriate, and provide clear reasoning for the decisions to those we take action against, especially in cases involving monetary penalties.

iv. Due process – those subject to enforcement action have the opportunity to make representations and provide mitigating information if a penalty is being considered, or as part of HMRC’s compound settlement process. There is also access to formal mechanisms for internal review of civil monetary penalties and, where applicable for civil and criminal action, the right to appeal to an independent court or tribunal.

Civil enforcement

20. Civil enforcement is not limited to monetary penalties. A monetary penalty is not always the most appropriate or proportionate response.

21. We consider potential breaches on the ‘balance of probabilities,’ which is the civil standard of proof. OFSI, OTSI and DfT assess any potential breach of a prohibition or failure to comply with an obligation on a strict liability basis. This means that, with the exception of ‘circumvention offences’ (where intent is required), there is no requirement to prove that a person had knowledge or reasonable cause to suspect they were in breach. However, as detailed below, knowledge may be an aggravating factor in the assessment of the seriousness of the breach and the enforcement outcome.

Civil enforcement at a glance

22. The table below summarises the range of civil enforcement tools available, along with potential mitigating and aggravating factors.

Potential actions	Potential mitigations	Aggravating factors
Warning letter Detention of transport assets Civil monetary penalty Referral to regulator/professional body Immigration action Disclosure Referral for potential criminal investigation	Prompt voluntary disclosure Cooperation Robust compliance systems in place Clean compliance history Swift remedial action taken	Deliberate behaviour Reckless or negligent behaviour Had required knowledge Previous non-compliance Significant harm caused Inappropriate compliance systems Concealment Repeated non-compliance

Civil enforcement actions

23. A wide range of civil enforcement tools are available, which may be used on their own or in combination. These include:

• warning letter – this may be used when the breach is minor and unintentional, low harm, a first-time breach, and/or remedial action has been taken.
• detention of transport assets – this may be used by DfT when a vessel or aircraft is owned (owned and/or controlled in the case of ships), chartered, or operated by a person connected with a sanctioned country or a designated person. It can also be used in instances where a vessel is specified, flying the flag of the sanctioned country or is registered in that country.
• civil monetary penalty – the use of this enforcement tool depends on the severity of the breach and the conduct of the breaching party. Previous compliance history, level of cooperation, whether the breach was voluntarily disclosed and the appropriateness of sanctions controls in place may be taken into account in determining the amount of the penalty. Penalties will only be imposed where doing so is in the public interest. The following sets out the statutory maximum for civil penalties:
  • The statutory maximum penalty amount for financial and trade sanctions breaches is £1 million or 50% of the value of the breach, whichever is greater.
  • OFSI ran a public consultation on revisions to its policies and penalty processes from 22 July to 14 October 2025. Following this, OFSI intends to double its statutory maximum penalty amount for financial sanctions to the higher of £2 million or 100% of the breach value. Introducing increased maximum penalties is intended to strengthen deterrence and increase OFSI’s flexibility to enforce breaches. This will require legislative change and will be taken forward when parliamentary time allows.
  • For transport sanctions the statutory maximum is the greater of £1 million or 50% of the estimated value of the ship/aircraft used in connection with the breach.
• referral to a regulator or relevant professional body – this may be used for regulated professionals or bodies to improve their compliance with financial sanctions. This can be in addition to other enforcement action.
• immigration enforcement action – where a person subject to an immigration sanction is in the UK having been refused entry or permission, or having had their permission cancelled, they may be liable to detention and removal from the UK.
• disclosure of breaches – may be used when breaches are confirmed.  Relevant considerations include whether it is in the public interest, beneficial for transparency and supports deterrence purposes because there are compliance lessons to be publicised.

24. We can also refer a case for criminal investigation and potential prosecution, this may be used when the breach is serious, deliberate or repeated. For further details on criminal enforcement criteria see the section below titled ‘Criminal investigation and enforcement’.

Civil enforcement: mitigating and aggravating factors

25. When considering enforcement action, including whether to impose a penalty and the amount, we assess relevant mitigating and aggravating factors. We take into account both the number and the nature of these factors.

26. Mitigating factors may contribute to a reduction in any potential civil monetary penalty, lead to us taking different enforcement action, or result in no enforcement at all. Aggravating factors may result in us determining that a more serious breach has occurred and could increase the severity of enforcement action.

27. The following list of mitigating factors and aggravating factors is not exhaustive. We may consider one or several factors when determining the outcome. Where both types of factors are evident, we assess them on a case-by-case basis.

Mitigating factors:

• voluntary disclosure – we encourage prompt and complete self-disclosure of breaches and will take this into account when making decisions on enforcement actions. It can also lead to a reduction being applied to a monetary civil penalty. For voluntary disclosure to be treated as a mitigating factor, it must be made as soon as is practicable, and before we become aware of the breach (rather than disclosure in response to a request for information). Disclosure must include all relevant facts and evidence available at the time. If only partial information is available, we prefer this to be submitted immediately, following up as soon as practicable with full disclosure to avoid a lengthy gap in notification.
• cooperation – we value cooperation and will take into account full, proactive cooperation with an investigation, including timely and complete responses and voluntary provision of relevant documents. In contrast, poor cooperation, delays or obstruction during an investigation can increase the severity of the case and reduce or eliminate any discounts.
• due diligence and compliance controls – we expect proportionate levels of due diligence (including ‘know your customer’) and appropriate systems to be in place to ensure compliance with all relevant prohibitions and obligations. If appropriate, you may wish to consider emerging technologies as part of proactively reducing or preventing risks. Inadequate or absent compliance controls, especially in regulated firms, may elevate the seriousness of the case.
• compliance history – a clean compliance record may support a lower penalty or alternative enforcement action, for example a warning letter. Repeated breaches, prior penalties or warning letters, or a pattern of persistent non-compliance can lead to higher penalties and referral for criminal investigation.
• remedial action – swift and effective remedial action post-breach to avoid future breaches, for example internal investigations, policy changes and a clear action plan to remedy defects, and clear evidence of its implementation, may be a factor in determining the enforcement outcome and level of penalty.

Aggravating factors:

• knowledge and/or intent – although we do not need to prove knowledge (except in circumvention cases), it is likely to be an aggravating factor if we assess that the person or business knew, or ought to have known, that their actions would be in breach. Where the behaviour was reckless, careless or risks were not appreciated or mitigated, we will likely assess such conduct as an aggravating factor but likely lower in seriousness than intended or deliberate actions. Where breaches are considered to be deliberate or intentional, these are likely to be classified as most serious breaches and may be referred for criminal investigation and potential prosecution.
• concealment – where steps are taken to conceal (or attempt to conceal) a breach, to obscure who was responsible or to hide relevant facts or evidence, we will likely assess this to be an aggravating factor. We may refer the case for criminal investigation and potential prosecution.
• extent of harm – breaches which risk or cause significant or lasting harm to the objectives of the sanctions regime/regulations, for example enabling sanctioned entities, are likely to be considered as more serious.

Compound settlements

28. Compound settlements can be used by HMRC to financially penalise businesses that have breached trade sanctions within HMRC’s remit, rather than referring the case for prosecution. If the business declines to pay a compound settlement, HMRC will continue its investigation with a view to referring the case for prosecution.

29. Compound settlements are used primarily where businesses have voluntarily disclosed sanctions offences to HMRC that were inadvertent or due to weaknesses in internal controls, cooperated with the investigation and sought to remedy any underlying failings. They are not used when there is evidence of intentional breaches.

30. For compound settlement cases, HMRC considers whether to name the company on a case-by-case basis. However, it is recognised that, for sanctions and export control breaches, naming could strengthen deterrence and improve compliance. HMRC is therefore reviewing its approach, including whether to publish more detail on the goods and locations involved.

Criminal investigation and enforcement

31. A breach of UK sanctions is a criminal offence. The maximum sentence on indictment is 7 years’ imprisonment, a fine or both for financial and transport sanctions breaches, and 10 years for trade sanctions breaches. A court may consider additional measures requested by prosecutors, such as Serious Crime Prevention Orders.

32. Criminal investigation and enforcement is used for the most serious or deliberate cases, and where the conduct involved is such that criminal enforcement is most appropriate. The relevant prosecution service must decide that the case has a realistic prospect of prosecution and that it is in the public interest to proceed with prosecution.

33. Examples of the kind of circumstances in which we will generally consider a criminal investigation include:

• cases involving organised criminal gangs or systematic non-compliance with sanctions
• where materially false statements are made or materially false documents are provided in the course of a civil investigation
• where deliberate concealment, deception, conspiracy, fraud or corruption is suspected
• cases involving the use of false or forged documents
• cases involving goods crossing the UK border in breach of prohibitions and restrictions
• where there have been previous offences or there is a repeated course of unlawful conduct or previous civil action
• where there is a link to suspected wider criminality
• where the value of the funds, goods, services or assets involved are significant

34. Our enforcement authorities and agencies reserve complete discretion over whether to conduct a criminal investigation in any case, and to carry out these investigations across a range of offences in all areas for which they have responsibility.

Criminal enforcement tools

35. Enforcement bodies use a range of criminal enforcement tools. These are designed to deter and address sanctions breaches effectively, while ensuring proportionality and fairness. These include:

• referral for prosecution – if HMRC, the NCA, the SFO or the police consider it appropriate following a criminal investigation, they can refer cases to the relevant prosecuting authority to determine whether there is sufficient evidence to prosecute and whether that prosecution is in the public interest.
• disruptions – a range of capabilities are used by HMRC, the NCA and its partners to disrupt criminal activity. This includes asset freezes and forfeiture, seizures of goods at the border and taking action against key enablers.
• disclosure – DBT will publish a notice in respect of businesses that have been convicted for breaching trade sanctions following investigation by HMRC. Where a business has been convicted, they will be named in the notice. The NCA also publishes details of those it investigates who are subsequently convicted.

Sanctions enforcement in action

36. Ensuring that UK sanctions are effective is a government priority, and we will continue to use all measures at our disposal to clamp down on breaches of UK sanctions. Sanctions investigations are complex, and both civil and criminal enforcement takes time, often years rather than months.

37. For operational security reasons, enforcement bodies are not able to disclose details of investigations before they are concluded. Doing so could prejudice the outcome of the case and risk giving the opportunity to destroy evidence or move assets.

38. Details of UK sanctions enforcement action can be accessed on GOV.UK: Sanctions enforcement action. This brings together enforcement notices, key lessons for industry, case studies and annual reviews from the UK’s sanctions enforcement bodies. Industry can use this resource to understand how breaches are identified and addressed, and to learn practical compliance lessons from real cases. For example, OFSI publishes monetary penalty decisions with “Notes on compliance,” highlighting common issues such as inadequate screening or failure to respond to information requests, whilst a HMRC case study shows how to help avoid inadvertent trade sanctions breaches.

Further details

39. For further sanctions content, including introductory guidance, statutory guidance, guidance by industry sector, sanctions lists and how to report a breach see:  UK Sanctions

Annex 1: Licensing and breach reporting framework

Government Authority	Licensing	How to apply	Reporting	How to report
Office of Financial Sanctions Implementation (HM Treasury)	Financial sanctions and the Oil Price Cap	How to apply for a financial sanctions licence	Financial sanctions    and the Oil Price Cap	Reporting information to OFSI - what to do
Office of Trade Sanctions Implementation (Department for Business and Trade)	Standalone services (including professional and business services)	Apply for a licence to provide sanctioned trade services	Services and trade in sanctioned goods, technologies and services (standalone and ancillary) outside the UK	Report a suspected breach of trade sanctions
Ofcom	n/a	n/a	Internet service sanctions	Ofcom website complaint form
Export Control Joint Unit (Department for Business and Trade)	Export of goods, military and dual-use items, technology and ancillary services	Applying for export licences using LITE or SPIRE   Guidance: Standard individual export licences	n/a	n/a
Department for Business and Trade	Import sanctions	Apply for an import licence	n/a	n/a
HM Revenue & Customs	n/a	n/a	Export controls (for military and dual-use goods and technology) and trade sanctions relating to imports and exports	Breaches of export controls and trade sanctions
Department for Transport	Transport	Transport sanctions: apply for a licence	Transport sanctions	Transport sanctions - Reporting obligations
Insolvency Service (Department for Business and Trade)	Director disqualification	Licence application for directors subject to director disqualification sanctions	Disqualified director	Report a disqualified director

1. There are a range of other departments that provide sector-specific advice on sanctions to inform policy, implementation and enforcement, including but not limited to: the Export Control Joint Unit; Department for Digital, Culture, Media and Sport; Department for Energy, Security and Net Zero; Department for Environment, Food and Rural Affairs; Department for Science, Innovation and Technology; Ministry of Defence and Ministry of Justice.  ↩

2. Cases involving suspected fraud may be referred to the Serious Fraud Office. Referrals may be made to police forces for criminal investigation if national agencies do not adopt the case. ↩

3. The Office of Trade Sanctions Implementation is responsible for civil enforcement for non-customs related trade sanctions. HMRC maintains enforcement ownership for trade sanctions offences that fall within its remit as the UK customs authority. ↩

4. For information on wider sanctions roles and responsibilities see Annex 1 to the Cross-government review of sanctions implementation and enforcement ↩