Sanction risks - OTSI plans to move from a REACTIVE to PROACTIVE enforcement
05/12/2025
The Office of Trade Sanctions Implementation (OTSI) is the UK’s civil enforcement body for trade sanctions, launched in October 2024 under the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024.
OTSIs remit covers enforcing sanctions related to the movement, provision, or acquisition of sanctioned goods, technology, and services outside the UK.
Criminal enforcement remains with HMRC, but OTSI can impose civil monetary penalties and refer severe cases for criminal investigation.
Key points from its first year (Oct 2024 – Oct 2025):
- OTSI received nearly 150 reports of potential breaches of trade sanctions in its first year of operation. [globalinve…review.com]
- It has built core capabilities, including compliance guidance, licensing administration, and industry engagement to prevent breaches before they occur. [gov.uk]
- Civil penalties can reach up to £1 million or 50% of the breach’s value, and enforcement is on a strict liability basis (no defence for lack of knowledge). Voluntary disclosure can reduce penalties by up to 50%. [sanctionsn…kenzie.com]
Looking ahead to 2026:
- OTSI plans to move from a reactive model to “proactive enforcement”, meaning more targeted investigations, data-led monitoring, and possibly publicising penalties to deter non-compliance. [assets.pub…ice.gov.uk]
- It will expand its licensing remit and increase support for businesses to comply with sanctions rules. [assets.pub…ice.gov.uk]
This shift signals a tougher UK stance on sanctions compliance, aligning with global trends toward stricter enforcement.
SOURCES
- https://assets.publishing.service.gov.uk/media/6931697c4bedc0e76230406b/OTSI_One_Year_Update.pdf
- https://www.gov.uk/government/publications/one-year-of-the-office-of-trade-sanctions-implementation-otsi/one-year-of-the-office-of-trade-sanctions-implementation-otsi
- https://globalinvestigationsreview.com/just-sanctions/article/uks-trade-sanctions-enforcer-reveals-investigations-underway
- https://sanctionsnews.bakermckenzie.com/new-uk-agency-and-civil-enforcement-powers-for-trade-sanctions-announced/
The Team
Meet the team of industry experts behind Comsure
Find out moreLatest News
Keep up to date with the very latest news from Comsure
Find out moreGallery
View our latest imagery from our news and work
Find out moreContact
Think we can help you and your business? Chat to us today
Get In TouchNews Disclaimer
As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.
As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.