Sanctions End‑Use Controls: What UK Exporters Need to Know

The UK has introduced a new “sanctions end‑use controls” licensing trigger aimed at restricting diversion of certain trade-sanctioned goods and related technology via non‑sanctioned third countries. The controls apply across all regimes with trade sanctions where restrictions extend beyond arms embargoes, and operates alongside, but separately from, export control “catch‑all” end‑use rules relating to military and weapons of mass destruction end-use concerns. The controls apply to goods, and technology related to the export of goods, that are subject to the relevant trade sanctions regime but are not otherwise subject to export controls.

Legislative Framework and Background
The Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 (Regulations) came into force on May 13, 2026, and make amendments to a wide range of UK sanctions regimes. Among other updates, they create a new offense of exporting certain sanctioned goods (or transferring related technology) to a non‑sanctioned country after the exporter has been “informed” of diversion risk.

This sits alongside the existing circumvention offenses in UK sanctions regulations, under which it is already an offense to intentionally participate in activities knowing that their object or effect is, directly or indirectly, to circumvent applicable sanctions prohibitions.

The controls have been introduced following the publication of the cross-government review of sanctions implementation and enforcement in May 2025, in which the government committed to consider introducing sanctions end-use licensing controls for exports with high risk of sanctions diversion in order to improve sanctions enforcement. For more information on some of the changes introduced in response to the cross-government review, see our earlier article.

Previously, UK exporters were not automatically required to obtain a license when exporting sanctioned goods and technology to non-sanctioned countries at risk of diversion to sanctioned countries or persons unless those items were already subject to strategic export controls. The government’s approach relied on informing businesses about diversion risks, although enforcement was limited. While existing rules prohibited the supply of sanctioned goods directly or indirectly to sanctioned countries via third countries, they did not empower the government to mandate licenses based solely on diversion risk. The new policy establishes a more robust framework for averting the diversion of sanctioned goods and technology.

To assist businesses potentially affected by the new rules, the Office of Trade Sanctions Implementation (OTSI) published official guidance on April 22, 2026, shortly after the Regulations were made by the Secretary of State.

Trigger for the Licensing Requirement
The new control only applies after an exporter is “informed by the Secretary of State” that the goods and/or related technology “are or may be intended” for export, transfer or use in a sanctioned destination or by a person connected with that destination. The informing step should take the form of a written notice identifying the shipment or transaction in scope and confirming that a license is required before export. From that point, it is prohibited to export those goods or transfer that technology without a license, even though the items are not on the UK’s strategic military/dual‑use control lists or subject to the UK’s WMD or military end-use controls. OTSI does not currently accept proactive license applications so exporters must wait to be “informed” before applying.

In practice, the “informing” step may happen at the border (for example, via HMRC’s national clearance hub) or directly from OTSI. Where goods have been stopped at the border, HMRC may either detain the goods, or allow them to be returned to the exporter, pending the outcome of the license application. The mere presentation of goods at the border before export should not itself constitute an offense; the offense arises if the exporter proceeds with the export after being informed that a license is required and without obtaining that license.

Compliance Expectations and Enforcement Risk
The government’s guidance reiterates that businesses should already be conducting risk‑based due diligence, with enhanced steps for higher‑risk goods and routes. In particular, exporters should review the UK’s Russia sanctions evasion guidance and the Russia Common High Priority List when assessing higher-risk goods, customers, intermediaries and routes. Evidence of due diligence carried out with respect to a specific shipment, as well as the exporter’s compliance history and due diligence processes as a whole, will be crucial factors that OTSI will take into account in its licensing decision. While blanket licensing requirements will not apply for specific goods routed to specific destinations, OTSI reserves the right to impose such requirements should the need arise.

The new framework gives the authorities an earlier intervention point, allowing them to stop or delay a shipment while the diversion risk is assessed and, where appropriate, require the exporter to substantiate the proposed end use, routing, customer profile and mitigation measures through the licensing process. For exporters, that makes contemporaneous records particularly important: If a notice is issued, evidence screening, diligence on intermediaries, contractual controls and escalation of red flags may determine whether the licensing process can be managed efficiently and effectively in their favor. For higher-risk transactions, exporters should consider obtaining specific end-use and no-re-export undertakings, alongside screening, intermediary diligence and route analysis.

Noncompliance risks include detention or seizure of goods, public naming and reporting by OTSI, monetary penalties up to the greater of £1 million or 50% of the value of the breach (which in some cases may be strict liability), and potential criminal investigation by HMRC. Consequences may also include refusal or revocation of existing or future export licenses.

Conclusion
Sanctions end-use controls are now live and close a meaningful enforcement gap, essentially acknowledging that existing sanctions regimes were not going far enough to punish those at whom they are targeted. If you are “informed,” you must obtain a license before proceeding. In practical terms, the relevant transaction should be paused, the factual record preserved, and the route, customer, end user, end use and mitigation evidence reviewed before any further steps are taken. Exporters should prioritize enhancing due diligence processes for high‑risk lanes and goods now, so that if a notice is issued they can move quickly with a credible, well evidenced license application.

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