The UK Government has introduced the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 (the “Regulations“), which will come into force on 12 May 2026 (see here).
The Regulations introduce Sanctions End-Use Controls (“SEUC“), a new licensing requirement which the UK Government can use to impose licensing requirements on exports where it considers there is a high risk of the goods or related technology being diverted to a sanctioned person or destination.
What are Sanctions End‑Use Controls?
SEUC are a new licensing requirement for exports to a non-sanctioned third country where the exporter has been informed by the government that there is a risk of ultimate diversion of the goods or related technology, via that route, to a sanctioned destination.
The controls will only apply to goods, and related technology, that are not otherwise subject to export controls. The measures are intended to complement existing “making available” prohibitions by enabling authorities to intervene before goods leave the UK, rather than relying solely on post‑export enforcement.
When do SEUC apply?
SEUC do not introduce blanket licensing requirements. A licence is required only once an exporter has been formally “informed” by the Office of Trade Sanctions Implementation (“OTSI“) or HM Revenue and Customs (“HMRC“) that a specific export is at high risk of diversion.
When being informed, exporters will receive information on how to apply for a licence. If an exporter has been informed, exporting without a licence will be in breach of UK sanctions and the goods in question may be detained at the border, or returned to the exporter, pending a licensing decision.
Sanctions regimes in scope
SEUC apply across all UK trade sanctions regimes where the restrictions extend beyond arms embargoes, meaning that the measures currently apply to goods and related technologies sanctioned under following sanctions regimes: Republic of Belarus, Democratic People’s Republic of Korea, Iran, Iran (Nuclear), Libya, Myanmar, Russia and non-government-controlled territories of Ukraine, Somalia, Syria, Venezuela, and Zimbabwe.
Licensing and enforcement
Licence applications will be assessed case‑by‑case, taking into account the nature of the goods; diversion risks linked to the customer, end user or route; the exporter’s compliance history and due diligence; and any additional intelligence available to the UK government.
Non‑compliance may result in detention or seizure of goods, monetary penalties, licence refusal or revocation, public naming, and potential criminal investigation.
The SEUC are being introduced via the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 (the “Regulations“), which will come into force on 12 May 2026.
The related guidance can be found here, which also includes case studies to illustrate how OTSI envisages SEUC operating in practice.
Other Updates to UK Sanctions under the Regulations
The Regulations introduce a series of targeted amendments across the UK sanctions framework. While largely technical in nature, the changes are relevant to a wide range of firms subject to UK sanctions obligations and are aimed at improving consistency and clarity.
- Reporting thresholds moved from euros to pounds
Across all UK sanctions regimes, monetary thresholds used to define certain relevant firms – including high value dealers and art market participants – are being updated so that they are expressed in pounds sterling (£) rather than euros (€). In particular, the existing €10,000 threshold is being replaced with a £10,000 threshold.
This change is intended to align sanctions reporting requirements with forthcoming amendments to the UK money laundering framework and avoid firms needing to operate across different currencies.
- Electronic service of licence notices
The Regulations confirm that the Office of Financial Sanctions Implementation and other competent authorities may issue notices for licences electronically, without requiring consent. This change reflects how authorities and businesses already communicate in practice.
- Clarification of HM Treasury debt exception
The scope of the Treasury debt exception is clarified to confirm that it applies to all transfers of funds across the payment chain, including transfers involving intermediaries.
