On 9 April 2026, the UK Office of Trade Sanctions Implementation (OTSI) announced that, from 27 April 2026, it will assume responsibility for licensing the export of sanctioned goods (and associated ancillary services) to sanctioned destinations (see here). Such licence applications will continue to be made and processed via the Department for Business and Trade’s (DBT) SPIRE system.
The change will add to OTSI’s existing responsibilities for licensing sanctioned standalone services (for example professional business services).
Overview of existing sanctions and export controls licensing regime
Within the DBT, responsibility for issuing trade sanctions and export control licences is shared between three bodies: OTSI, the Import Controls and Sanctions team, and the Export Control Joint Unit (ECJU).
OTSI currently administers a sanctions‑specific licensing regime solely for certain standalone trade services. Applications for such licences are made to OTSI via the OTSI online portal.
By contrast, the ECJU is currently broadly responsible for licensing the export from the UK of controlled goods, software and technology including sanctioned goods, software and technology and military and dual‑use goods, software and technology appearing on the UK’s consolidated strategic export control list (and the provision of ancillary support such as technical assistance and brokering). Licence applications in relation to such controls, as well as where there are concerns regarding end‑use or the end‑user(s) (as applicable), are made via SPIRE.
Responsibility for issuing financial sanctions licences lies with the Office of Financial Sanctions Implementation within HM Treasury.
Updated licensing approach and impact to application process
From 27 April 2026, OTSI will take over responsibility for licensing the export of sanctioned goods (and associated ancillary services) to sanctioned destinations. The ECJU will retain responsibility for issuing licences for goods and ancillary services that are subject to both sanctions and strategic export controls, as well as goods subject to export controls only.
For the time being, the licence application process will remain largely unchanged, with licence applications for sanctioned items and associated ancillary services continuing to be submitted through SPIRE. Licence applications for standalone services will also continue to be submitted via the OTSI online portal.
From 27 April onwards, OTSI will become responsible for assessing SPIRE applications for the export of sanctioned goods and associated ancillary services controls. Where a licence is required, OTSI will issue a Standard Individual Export Licence (SIEL) via SPIRE. This is consistent with the process currently followed by the ECJU. Issuing a SIEL through SPIRE will also ensure that licences authorising the movement of goods are visible to HM Revenue & Customs (HMRC), and Border Force.
Looking forward
OTSI has indicated that further information and updated guidance on export sanctions licensing will be published ahead of 27 April, including updates to statutory guidance clarifying which licensing body is responsible for which sanctions prohibitions.
