Guidance

How OTSI assesses application for trade sanctions licences

This guidance is for applications submitted to OTSI seeking licences to carry out sanctioned activity related to both services and goods.

From:
Department for Business and Trade and Office of Trade Sanctions Implementation
Published
23 April 2026

Activities

OTSI’s assessment process has been carefully designed to mirror trade prohibitions in sanctions regulations.

Once OTSI has received your application, it will assess how the relevant sanctions regulations apply to each of the ‘activities’ described in your application.

One ‘activity’ is regarded as one prospective licensee providing activity you consider to be prohibited under one regulation to one prospective recipient (the planned recipient of the goods or services). For example:

  • if you are applying for a licence on behalf of one prospective licensee who wishes to export a laptop and a camera to one prospective recipient in Russia, OTSI will view this as two activities because there are two types of goods planned for export from the prospective licensee to the prospective recipient, and therefore two types of planned exports which need to be assessed against the regulations
  • if you are applying for a licence on behalf of one prospective licensee who wishes to export petroleum jelly to five prospective recipients in Russia, OTSI will view this as five activities because there are five planned paths of exports of petroleum jelly into Russia, one to each prospective recipient
  • if you are applying for a licence on behalf of three prospective licensees who all wish to provide engineering services to one prospective recipient, OTSI will view this as three activities because there are three chains of planned service provision to the prospective recipient, one from each prospective licensee
  • if you are applying for a licence on behalf of one prospective licensee to provide engineering services and accounting services to one prospective recipient, OTSI will view this as two separate activities because there are two types of planned service provision from the prospective licensee to the prospective recipient

OTSI will still consider any connections between the activities in a licence application and factor this into their assessment.

For each activity in your application, OTSI will assess:

  1. Whether UK sanctions apply to the prospective licensee
  2. Whether UK sanctions apply to the prospective recipient
  3. Whether the activity described in your application is sanctioned
  4. Whether the purpose of the activity you wish to carry out is consistent with the purposes of the sanctions

These are used to establish whether the activity you wish to carry out is prohibited under the relevant sanctions regulations, and whether it requires a licence to be undertaken lawfully.

If a licence is not required for the activity to be undertaken lawfully, OTSI will issue you with a notification that No Licence is Required (‘NLR’).

If the activity you wish to carry out is prohibited under UK sanctions and a licence is required for it to be undertaken lawfully, OTSI will conduct assessment 4 to determine whether it should license the activity.

The guidance below provides more information on how each stage of OTSI’s assessment is conducted and what you need to include in your licence application to support this assessment.

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.

Assessment 1: Whether UK sanctions apply to the prospective licensee

OTSI refers to the party or parties you wish to be named on the licence as ‘prospective licensee(s)’.

OTSI will carry out an assessment of whether Section 21 of the Sanctions and Anti-Money Laundering Act 2018 (SAMLA) applies to the prospective licensee by looking at whether the activity would be carried out within the UK or its territorial seas, or whether the prospective licensee meets the definition of a “UK person” under Section 21(2) if the activity would be carried out extraterritorially.

You’ll need to include the names and addresses of the prospective licensees to support OTSI in making this assessment. If the prospective licensee is a company incorporated in the UK, you’ll need to include its registered number. If the prospective licensee is an individual with UK nationality, you’ll need to include a copy of their British passport.

If you are submitting an application on behalf of a group of individuals and you cannot provide their names and addresses, you’ll need to provide information about how the compliance of these individuals with the terms of any licence granted will be monitored without this information. It will be a condition of any licence issued that records of sufficient detail must be maintained and could be inspected by any person authorised by the Secretary of State or the Commissioners for His Majesty’s Revenue and Customs. As part of OTSI’s assessment, the ability of the UK nationals to comply with all terms of a licence, including these record-keeping requirements, will be considered.

Assessment 2: Whether UK sanctions apply to the prospective recipient

OTSI refers to the planned recipient of the goods or services you wish to provide as the ‘prospective recipient(s)’.

OTSI will carry out an assessment of who the prospective recipient is and where they are based to determine how UK sanctions apply to them. This includes checking the UK Sanctions List to determine whether they are designated or specified under regulations made under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA).

Some prohibitions in some sanctions regimes contain additional provisions which OTSI will consider during this assessment. For example, if you are applying to carry out some activity prohibited under the Russia (Sanctions) (EU Exit) Regulations 2019, OTSI will consider whether the prospective recipient meets the definition of a person “connected with” Russia if relevant.

You’ll need to include the names and addresses of the prospective recipient to support OTSI in making this assessment. If the prospective recipient is a company, you’ll need to tell OTSI where it is incorporated. You’ll also need to provide OTSI with details of its ownership structure. You may wish to provide this in the form of an organogram of the group structure. If the prospective recipient is an individual, you’ll need to tell OTSI which nationalities they hold, and if possible, include a copy of their passport(s).

Assessment 3: Whether the activity described in your application is sanctioned

OTSI will carry out an assessment of whether the activity described in your application is sanctioned by determining whether it meets the definition of the relevant prohibited activity in the regulations. Where relevant, OTSI will consult other teams in HM Government to carry out this assessment.

You’ll need to describe in detail the specific activity you want to carry out and why you consider it to fall under the definition of the relevant prohibited activity in the regulations.

If you’re applying for a licence to export, transfer or make available goods or technologies not subject to strategic export controls, you’ll need to include a clear product description and technical specifications for each product or type of product, including their commodity codes, and a detailed description of what they’ll be used for. You can find commodity codes for goods using the Trade Tariff service. You should also include information on any transit routes, shipping documentation, and details of any due diligence you have carried out, including how you have considered the risk of diversion. 

If you’re applying for a licence to provide a service in relation to goods or technologies which are not subject to strategic export controls (ancillary services), you’ll also need to provide OTSI with the details of the commodity codes of the goods or technologies, and a detailed description of what they’ll be used for. You’ll also need to provide a detailed description of the services which would be provided. In this description, you should explain clearly why you consider this activity to fall under the definition of the prohibited activity in the regulations.

If you’re applying for a licence to provide services which are not related to goods or technologies (‘standalone services’), such as professional and business services prohibited under the Russia (Sanctions) (EU Exit) Regulations 2019, you’ll need to provide a detailed description of the services and explain clearly why you consider this activity to fall under the definition of the prohibited activity in the regulations. Some definitions of prohibited services use Central Product Classification (CPC) codes and Extended Balance of Payments Services (EBOPS) classifications. Where this is the case, you’ll need to tell OTSI which codes apply to the activity you wish to carry out.

Please note that the export, transfer and making available of goods and technology subject to strategic export controls and also prohibited under UK sanctions is licensed by the Export Control Joint Unit (ECJU) so that exporters do not have to seek licences from both ECJU and OTSI. Read more about the split of Trade sanctions licensing responsibilities.

Assessment 4: Whether the purpose of the activity you wish to carry out is consistent with the purposes of the sanctions

OTSI has a statutory duty to protect the integrity and purpose of the UK’s sanctions regimes. The fundamental statutory purpose of any sanctions regime made under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA) is to prohibit activity. A licence is an exception to that prohibition. OTSI’s role is to determine whether to allow a licence. 

OTSI can only grant a licence if the purpose of the activity you wish to carry out is consistent with the purposes of the sanctions. The purposes of each sanctions regime are set out within Part 1 of the relevant regulations and accompanying guidance.

If OTSI has determined that the activity you wish to carry out requires a licence to be carried out lawfully, there are likely to be reasons why the activity is not consistent with the purposes of the sanctions. For example, if you’re seeking a licence to provide professional and business services prohibited under the Russia (Sanctions) (EU Exit) Regulations 2019, it is likely that the provision of these could generate revenue for the Russian economy, which could in turn be used by the Russian government to fund the war in Ukraine. The sanctions on the provision of these services are intended to prevent this in order to increase economic pressure on Russia. However, there may be other reasons why the purpose of the activity is consistent with the purposes of the sanctions.

For some sanctioned activity, there are some activities which the Department for Business and Trade (DBT) considers likely to be consistent with the purposes of the sanctions. These pre-defined activities are known as licensing considerations. If you’re applying under any of these licensing considerations, you’ll need to consider and demonstrate in your application how the purpose of the activity you wish to carry out aligns with one, or more, of these licensing considerations. 

You can find all the pre-defined licensing considerations in the relevant statutory guidance:

As part of this stage of the assessment, OTSI will assess whether the licensing consideration(s) you have applied under applies to the purpose of the activity you wish to carry out. You’ll need to demonstrate a direct link between the purpose of the activity and the licensing consideration.

For example, if you apply for a sanctions licence to carry out the export of goods prohibited under regulation 46Y of the Russia (Sanctions) (EU Exit) Regulations 2019 using the licensing consideration which states that ‘a licence may be granted for the export, making available, supply, or delivery of 7 dependency and further goods or technology for medical and pharmaceutical purposes, provided that this is for the benefit of the civilian population’, you’ll need to demonstrate to OTSI how the export of these goods directly impacts the production or supply of medical and pharmaceutical goods or services to the Russian civilian population. You may wish to further demonstrate this by explaining what the impact on this production or supply would be were OTSI not to license the export of the goods.

You can still apply for a sanctions licence from OTSI if there are no pre-defined licensing considerations for the regulation you consider the activity you wish to carry out to fall under, or if the activity you wish to carry out does not align with any of the licensing considerations which are available.

Whether or not a licensing consideration is applicable to the activity the licence is being sought for, OTSI will undertake a wider assessment of whether the purpose of the activity you wish to provide is consistent with the purposes of the sanctions. This assessment is carried out on a case-by-case basis according to the UK’s foreign policy objectives at the time of the assessment, to the extent that they are relevant to the operation of the sanctions regime. This assessment is often finely balanced.

You’ll need to set out in detail why the purpose of each activity you are seeking a licence for is consistent with the purposes of the sanctions. You can provide supporting documents where applicable, such as control structure charts, or detailed plans for divestment or wind-down of operations. You may also wish to set out what the impact would be were OTSI not to license you to carry out the sanctioned activity.

You should also include a clear explanation of when, or how frequently, the activity will take place.

For detailed information read the guidance on how to apply for a trade sanctions licence from OTSI.

Updates to this page

Published 23 April 2026

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