New figures released for export controls fines against UK exporters show enforcement on the increase

The Department for International Trade has revealed in a notice to exporters that HMRC has received settlements totalling £700,368.01 for export control violations between March and September 2020.
Fines of up to £211,250 were issued to exporters across 19 settlement actions for unlicensed exports of dual use goods, military goods and related activity controlled by the Export Control Order 2008. This is the highest annual total for export control fines to date.
HMRC has a discretionary power to impose civil monetary penalties in lieu of criminal prosecution for violations of the UK’s export control laws. These powers to issue monetary penalties exist alongside prosecutorial enforcement options, which can result in the imposition of criminal fines or imprisonment. Depending on the seriousness of the offence, any intent, compliance steps taken, and other aggravating and mitigating factors, HMRC may decide to issue a compound penalty, for example if the exporter has taken remedial actions to correct compliance issues and has voluntarily made a full and comprehensive disclosure of violations.