On 10 March 2026, the UK Government published a policy paper outlining the UK’s approach to enforcing sanctions breaches (available here). The policy paper sets out that “[r]obust enforcement of UK sanctions is a priority for this government”. The paper “brings together information on civil and criminal enforcement of sanctions across government departments and agencies”, and “sets out [the UK Government’s] overarching enforcement principles, and details the range of enforcement tools available, along with the mitigating and aggravating factors taken into account in enforcement decisions”.
The policy paper notes that the UK Government’s approach to sanctions enforcement is driven by four key principles, namely:
- Driving compliance: This can be effected “through guidance and engagement”.
- Proportionality and fairness: Enforcement “should be proportionate to the nature and impact of the breach, and consistent with the purpose of UK sanctions”. The UK Government will evaluate “each suspected breach individually, considering the specific facts, context, and applicable regulations”, and take into account aggravating and mitigating factors.
- Transparency: The UK Government will “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”.
- Due process: The policy paper notes that “those subject to enforcement action have the opportunity to make representations and provide mitigating information”. There are also mechanisms for review and appeal of penalties.
The paper emphasises that the UK Office of Financial Sanctions Implementation, the UK Office of Trade Sanctions Implementation, and the Department for Transport are all able to take enforcement action on a “strict liability” basis – i.e. these authorities are able to take enforcement action without needing to prove that a party knew or had reasonable cause to suspect that it was acting in breach.
The policy paper also includes a discussion of HMRC’s approach to imposing compound settlements for breaches of trade sanctions, which typically involve companies remaining anonymous. The paper notes that “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.” These sentiments were similarly reflected in the recent comments made by HMRC at a Business and Trade Sub-Committee on Economic Security, Arms and Export Controls Meeting held on 25 February, in which HMRC confirmed they are in the early stages of “looking at options for giving themselves the powers to have greater legal powers to name [companies]”.
This publication follows the UK Government’s previous cross-government review of sanctions implementation and enforcement, from May 2025 (available here).
Please do reach out to our team if you would like to discuss any of the issues in this post.
