Guidance

Apply for a licence to carry out sanctioned trade through OTSI

Check if you need a licence from the Office for Trade Sanctions Implementation (OTSI), and apply online.

From:
Department for Business and Trade and Office of Trade Sanctions Implementation
Published
10 October 2024
Last updated
23 April 2026 — See all updates

What a sanctions licence from OTSI allows you to do 

A sanctions licence from OTSI allows you to carry out certain trade activity that would otherwise be prohibited under sanctions legislation, including the: 

  • would otherwise be prohibited under sanctions legislation, including the: export, transfer, and making available of goods and technology not subject to strategic export controls
  • provision of services ancillary to a good or technology, where the good or technology the services relate to is not subject to strategic export controls
  • provision of professional and business services prohibited under the UK’s sanctions on Russia
  • provision of other standalone services (services not related to a good or technology)

The sanctions regulations relating to these prohibited activities are: 

When you need a sanctions licence from OTSI

UK sanctions apply to you if you have a link to the UK, known as a UK nexus. This means:

  • all individuals or businesses within the territory and territorial sea of the UK

  • all UK nationals or UK businesses, wherever they are in the world

If you have a UK nexus and you want to carry out activity which is prohibited under sanctions regulations, and no general trade licences or exceptions apply to that activity, you will need to apply for a licence. You can find more information on the general trade licences or exceptions which could apply to the activity under the statutory guidance for the relevant sanctions regime.

OTSI can only advise on whether you require a licence or not if you submit a licence application. This is because OTSI requires detailed information about the activity you wish to carry out in order to make this assessment.

Other types of trade sanctions licences

You cannot apply to OTSI for a licence covering the:  

  • export, transfer, or making available of goods or technology prohibited under UK trade sanctions, where the goods or technology are also subject to strategic export controls

  • provision of sanctioned services relating to goods or technology which are subject to strategic export controls (some ancillary services)

  • import of goods prohibited under UK trade sanctions, and the provision of related ancillary services

The statutory guidance for each UK sanctions regime which contains prohibitions on trade activity includes guidance on which licensing body has responsibility for licensing which prohibition. Find out more information about the application process.

If your business does not have a UK nexus

If your business does not have a UK nexus, but it has, for example, employees or consultants who have a UK nexus and will be carrying out the sanctioned activity on behalf of the business, you’ll need to apply for a licence for these named individuals only. This is covered in the guidance on how applications are assessed.

Who is covered by a sanctions licence from OTSI

A sanctions licence from OTSI authorises all named parties (the ‘licensees’) to carry out the specified activity only, for the period stated.

Once you’re authorised by a licence, you must follow its terms. If you do not, you may be committing a breach of trade sanctions and could be subject to enforcement action.

You’ll need to select who you want the licence to authorise. A licence authorises either:

  • a business, or businesses, with a UK nexus (the licence will usually cover all employees, members, partners, consultants, contractors, officers and directors) 

  • named individuals with a UK nexus working for a business with no UK nexus (for example, if your business has no UK nexus and therefore cannot be licensed, but you have employees or consultants with a UK nexus who will be carrying out the sanctioned activity) 

  • yourself as an individual (for example, if you’re a sole trader and not able to apply under a business with a UK nexus) 

If you’re naming any individuals on the licence, you should get their consent before you apply. Individuals within the territory and territorial sea of the UK, and UK nationals wherever they are in the world, must comply with UK sanctions, and are personally liable for their compliance.

A third party, such as a legal adviser, can apply on your behalf. They will need to upload a letter of instruction to the application to show they have your permission to act for you. 

What you need to show in your application 

You’ll need to ensure your application contains all the information which OTSI needs to complete its assessment of the activity you wish to carry out. More guidance on how OTSI carries out its assessment of trade sanctions licence applications, and the information it requires to do this, is available.

You may wish to provide a cover letter with your application to enable you to fully describe the activity you wish to carry out in the level of detail OTSI requires to assess it. Your cover letter should be dated within the last month. Applications submitted with out-of-date cover letters will be automatically closed.

You may wish to separate the activities you are seeking a licence for in your cover letter to enable you to fully describe each one.

You should not assume that OTSI knows anything about the activity you are wishing to carry out. OTSI cannot make assumptions about the activity, and you should therefore provide detailed information submissions to support OTSI’s assessment.

If you have previously submitted related information to OTSI, the Export Control Joint Unit (ECJU), or another government body as part of another licence application, you should resubmit this if you wish OTSI to consider it as part of its assessment.

If more information is required for OTSI to complete their assessment

OTSI may write to you during its assessment to request additional information required to continue its assessment. These letters are called Requests for Further Information (‘RFIs’).

If sufficient detail is not provided in your initial application, OTSI may request you provide further information including:

  • name of activity described in your application
  • name and address of the prospective licensee
  • name and address of the prospective recipient
  • full description of the activity they wish to provide (including commodity codes for goods) and which regulation you consider it to be prohibited under
  • reason you consider the purpose of this activity to be consistent with the purposes of the sanctions.

Where OTSI does not receive the level of detail it requires in your responses to RFIs, it may send you another RFI containing rephrased or different questions in order to get the information required. OTSI will always explain why it is asking you these questions.

If the information OTSI requires is not forthcoming – either because of a lack of response or responses with inadequate detail or clarity – OTSI will close your application. OTSI will always notify you when it does this.

What you can expect from the outcome of OTSI’s assessment

OTSI has developed a rigorous licensing process through which we assess whether to license otherwise prohibited trade on a case-by-case basis, against the applicable licensing considerations and the purposes of the sanctions as set out in legislation. Read more about the process in our guidance on how applications are assessed.

OTSI will provide you with a detailed assessment of how UK trade sanctions apply to each activity described in your application to support you to trade compliantly with confidence. For this reason, you may receive multiple outcomes for one licence application. For example, you may be informed that you have been licensed to carry out two activities described in your application, but that you do not require a licence to lawfully undertake a third activity described in your application because it is not prohibited under the UK’s trade sanctions.

If OTSI determines the activity you wish to provide should be licensed, you will receive an electronic copy of the licence. Licences for goods or technology which will cross the UK border will be provided to HMRC by OTSI as soon as they are issued.

If your application for a licence is refused, you can apply for a licence from OTSI again. Please note that, unless you provide new information as part of this application, you are unlikely to receive a different decision.

How long a licence is valid for

In your application, you’ll need to explain for how long you require any licence to be granted and why.

There is no minimum duration for an OTSI licence. The standard maximum duration of an OTSI licence is 24 months. However, in very exceptional circumstances, OTSI may consider licensing an activity for longer. You should set out in detail why you are seeking a licence of longer than 24 months if you wish OTSI to consider this.

Renewing a licence 

You must apply for a new licence if you want to: 

  • renew it 
  • add or remove details that affect the coverage of the licence, such as the nature of the activity, the licensees or the recipients 

Please note that, if you include new information as part of your application to renew a licence which may change what activity or who the licence covers, OTSI will not consider the application to be a renewal and will consider how these changes affect its assessment.

If your previous licence has lapsed before you apply to renew it, you must explain why you did not apply to renew it sooner. Allowing your previous licence to lapse may suggest that the activity you are seeking a licence for is not essential, and this may affect OTSI’s assessment of whether its purpose is consistent with the purposes of the sanctions. Once a licence has lapsed, the activity must stop. Any continuation of activity without a valid licence could be a criminal offence.

Before submitting a renewal application, applicants may wish to review the guidance on how OTSI carries out its assessment of whether the purpose of the activity you have described in your application is consistent with the purposes of the sanctions. This section sets out that the purpose of the activity or activities described in the application are assessed against the stated purposes of the sanctions and the UK’s foreign policy at the time of the assessment, to the extent that it is relevant to the operation of the sanctions regime. OTSI’s determinations on whether the purpose of an activity is consistent with the purposes of the sanctions may change over time.

Timescales for assessment

You must not engage in any activities prohibited by trade sanctions unless and until you have a valid licence.

The time taken to assess a licence application is dependent on how many activities a licence is sought for, and how complex they are.

OTSI manages high volumes of sanctions licence applications. You should allow 6 months minimum for a licence assessment to be completed. OTSI always works hard to conclude applications as soon as possible and its average time for concluding applications since its launch in October 2024 is 82 working days, which includes the time taken by applicants to reply to requests for information. Prompt responses to any requests for further information from OTSI will support OTSI to deliver an outcome as soon as possible. OTSI will contact you if it will be unable to conclude its assessment within this timeframe.

OTSI’s caseload means it cannot provide bespoke updates on how your application is progressing during the assessment process and enquiries seeking an update will receive a generic response.

Please also note that OTSI cannot respond to correspondence from anyone who is not listed as a contact on your licence application. If an alternative contact wishes to correspond with OTSI about your licence application, please contact OTSI in advance to authorise this engagement.

Data protection and retention

OTSI consults advisory teams across the government, and occasionally counterparts in relevant countries, in order to complete its assessment of licence applications. You should make OTSI aware when submitting information should you have any specific handling requests, and if you are applying or have applied for a relevant licence from any other jurisdictions.

Licences issued by OTSI are public documents. While they are not published online, prospective licensees should be aware of this. Licensees’ names and addresses are included on the licence. If prospective licensees have concerns about the inclusion of their information on any licence granted, they should make OTSI aware during the licence application process.

All information provided to OTSI as part of your licence application will be retained for a period of 15 years from the expiry date of any licence issued, or from the date the case was closed if a licence was not granted.

Apply for a licence from OTSI

How you need to submit a licence application to OTSI depends on the type of activity you are seeking a trade sanctions licence for.

How to apply for a licence to provide sanctioned professional and business services and other standalone services through OTSI’s online application service

Since its launch on 10 October 2024, OTSI has been responsible for the trade sanctions licensing of standalone services (services not related to a good or technology) prohibited under the UK’s trade sanctions, including professional and business services prohibited under the UK’s sanctions on Russia. These services are:

  • professional and business services (under the Russia sanctions regime) 
  • accounting 
  • advertising 
  • architectural 
  • auditing 
  • business and management consulting 
  • engineering 
  • public relations 
  • energy-related services (under the Russia sanctions regime), such as drilling, well testing, logging and completion services or the supply of specialised floating vessels  
  • infrastructure or tourism-related services to non-government-controlled Ukrainian territories (under the Russia sanctions regime) 
  • interception or monitoring services (under the Russia, The Republic of Belarus, Iran, Myanmar, Syria and Venezuela sanctions regimes) 
  • mining, manufacturing or computer services (under The Democratic People’s Republic of Korea sanctions regime) 
  • ships or aircraft-related services (under The Democratic People’s Republic of Korea sanctions regime), such as leasing and chartering, crew services, ship classification services, bunkering or ship supply services 

Applications for licences to provide these services should continue to be submitted through OTSI’s online application service using the ‘Start Now’ button below.

Once OTSI has completed the assessment of your licence application, an outcome letter and any licence issued will be emailed to you.

You now need a GOV.UK One Login to use OTSI’s online licence application service. You’ll be able to create a GOV.UK One Login account if you do not already have one. You can also use your GOV.UK One Login to access other government services.

Please note that, if you are seeking a licence on behalf of multiple UK nationals but you cannot provide their names or addresses, OTSI suggests you follow the ‘business or businesses with a UK nexus’ route on the application service. This will eventually bring you to a page which will allow you to specify that the business is located outside of the UK. On the ‘Business details’ page, please enter the ‘Name of the business’ as ‘UK nationals employed by [name of company], which has no UK nexus’. As set out in the guidance on how applications are assessed, you will need to provide alternative information to the individuals’ names and addresses to ensure OTSI has the information it requires to assess the licence application.

Start now

If you’re unable to use this service, contact OTSI. 

How to apply for a licence to export, transfer, or make available goods and technology not subject to strategic export controls, and associated ancillary services, through DBT’s SPIRE system

On 27 April 2026, OTSI assumed responsibility for the sanctions licensing of the export, transfer, and making available of goods and technology which are not subject to strategic export controls, and associated ancillary services, from the Export Control Joint Unit (ECJU). For now, applications for licences to carry out this activity should continue to be submitted through DBT’s SPIRE service.

You’ll need to apply for a Standard Individual Export Licence (SIEL) on SPIRE and following the guidance. Read the general guidance on using SPIRE.

OTSI’s assessment process has been designed to mirror trade prohibitions in sanctions regulations and more guidance on this assessment process is available. For applications made via SPIRE, please attach a cover letter setting out the information required for OTSI to carry out its assessment.

Upon submitting the application, you will be issued with a SPIRE reference number.

Once OTSI has completed its assessment of your application, you will receive an outcome letter. A licence (if applicable) will be issued via SPIRE. Please note that OTSI licences issued through SPIRE will be in ECJU’s standard format for Standard Individual Export Licences (SIELs) rather that OTSI’s standard licence format. This means you may not see an OTSI logo on the licence. OTSI and ECJU both issue trade sanctions licences under the authority of the Secretary of State for Business and Trade, and therefore the licence you receive will still be recognised by HMRC and other inspecting authorities. The accompanying outcome letter, via email, will make clear that the licence has been issued by OTSI.

Unfortunately, we are currently unable to issue licences for applications where licences for some activities have been refused, or do not require a licence, due to the limitations of the SPIRE system. If you have been licensed to carry out some activity described in your application, but not all of it, you will receive an outcome letter from OTSI via email asking you to submit a further licence application on SPIRE for the activities you have been granted a licence for only, and we will issue the licence as soon as possible. If you are planning to submit a licence application on SPIRE covering a wide range of activity, you may wish to consider splitting this into a number of narrower applications.

We understand that this is an imperfect solution for applicants and are grateful for your patience while we continue to use SPIRE for these licences. We have opted to use SPIRE for now in order to minimise disruption for exporters. Any communications or documentation you receive from OTSI outside the SPIRE system is legitimate DBT correspondence.

If you’re unable to use SPIRE, contact ECJU’s helpdesk by emailing exportcontrol.help@businessandtrade.gov.uk.

Get help 

If you’re unsure whether this is the right type of trade sanctions licence for your activities, contact OTSI using the enquiry form before submitting your application.

Updates to this page

Published 10 October 2024
Last updated 23 April 2026 show all updates

  1. Changes to OTSI licencing responsibilities and update on application processes.

  2. Webpage title and URL updated from 'Apply for a licence to provide sanctioned trade services' to 'Apply for a licence to carry out sanctioned trade through OTSI'.

  3. 'Using GOV.UK One Login' section outlining changes to how users access the online service removed. Text added to 'Apply for a services licence' section to reflect that, from 23 October, users can use GOV.UK One Login to access the online service.

  4. added a GOV.UK One Login section, which explains that a GOV.UK One Login will be needed to access the service in the future. This section will be removed once the login is active.

  5. Combined the two sections on purposes and licensing grounds: to give clarification that licensing grounds are examples of activities which the Department for Business and Trade (DBT) considers align with the purposes of the sanctions. Added examples of information you may need to gather before you start. Added explanation of why the Office of Trade Sanctions Implementation (OTSI) cannot give a response timescale to applications,

  6. The following licensing ground has been removed: services to a person connected with Russia by a UK parent company or UK subsidiary of that parent company 

  7. First published.

Sign up for emails or print this page

Contents

Related content