On 4 December 2025, the UK Office of Trade Sanctions Implementation (“OTSI”) published a corporate report marking the first year since its launch in October 2024 (see here). Our previous blog post providing more background on OTSI’s powers and jurisdiction can be found here.
The corporate report summarises OTSI’s activities during this first year, including licensing and enforcement activity, efforts to engage with businesses, collaboration with international partners and other government functions, as well as OTSI’s future priorities (notably including an expanding licensing remit). A detailed annual review for the 2025-2026 financial year is expected to be published in 2026, providing more information on OTSI’s performance during that year.
Key points presented by OTSI in its report are summarised below.
OTSI License Application Statistics
At present, OTSI issues licences for professional, business, and other standalone services restricted by UK trade sanctions. As of 09 October 2025:
- OTSI received 60 licence applications, the “vast majority” of which concerned applications for the provision of professional and business services under the UK’s Russia sanctions. OTSI has completed its review of 28 of these applications, resulting in the granting of 12 full or partial licences with the remainder refused, withdrawn or marked as mistakes or classified as no licence required.
- OTSI is currently processing 32 licence applications, with the average processing time for an application being 82 working days (including time for requests for further information).
OTSI is also expected to publish further guidance on the application and assessment process with the intention of expediting application reviews, including by providing guidance to help applicants better understand the application process and to improve associated information provided.
Investigations and Enforcement
- To date, OTSI has received 146 breach reports and has a number of investigations underway. The majority (84%) of reports came from sectors to which mandatory reporting obligations apply, in particular the financial services sector.
- OTSI has also made a “significant” number of referrals to HMRC and other government partners and has shared information with international counterparts in line with OTSI’s regulatory powers.
- As of this blog, no civil monetary penalties have been issued by OTSI.
- OTSI has also stated its intention to publish reports about breaches to support businesses in improving compliance.
Business Engagement
- OTSI has sought to work with UK businesses by engaging with stakeholders over 200 times through forums, workshops, webinars, and meetings, and has handled over 210 stakeholder queries.
- In March 2025, OTSI launched a free shared subscription platform for sanctions updates (in partnership with the Office of Financial Sanctions Implementation “OFSI” and the Foreign, Commonwealth and Development Office (“FCDO”)). This platform publishes sanctions updates from all three bodies, aimed at simplifying the notification process for stakeholders.
- The targeted outreach and guidance published by OTSI has focused on helping businesses comply with sanctions, in particular in identifying Russian sanctions evasion tactics and supporting enhanced due diligence.
International and Cross-Government Collaboration
- OTSI has strengthened relationships with international partners including in the US, Europe, the G7 more broadly, and beyond, through formal exchanges, sharing lessons, as well as case referrals.
- OTSI has supported the UK Government’s international sanctions technical assistance programme, by supporting and providing advice to the Crown Dependencies, Overseas Territories, and Cyprus in setting up and bolstering sanctions implementation and enforcement functions. This in the context of a key priority of OTSI to support the development of robust, coordinated global sanctions regimes.
- OTSI has contributed to a cross-governmental sanctions implementation and enforcement review led by the FCDO and is working closely with the FCDO, OFSI, HMRC and other public bodies to take forward associated recommendations, including to develop enforcement strategy and publish clearer guidance.
Looking ahead
- OTSI’s licensing remit will grow in early 2026 to cover all export sanctions licensing (except for activities involving goods and technology subject to strategic export controls, which will remain with the Export Control Joint Unit (“ECJU”)). At present, ECJU also handles licence applications concerning the supply of ancillary services relating to items subject to sanctions.
- The report notes that OTSI will expand its business engagement, especially outside London, and continue its trade sanctions roadshow.
- OTSI also aims to deliver more proactive enforcement, including by developing capabilities to use actionable intelligence and improving cross-government collaboration on intelligence sharing and analysis.
