OTSI publishes first annual report

5 December 2025

The UK’s Office of Trade Sanctions Implementation (OTSI) has published a review of its first year of operation. OTSI was established in 2024 and is responsible for the licencing and the civil enforcement of certain trade sanctions.

Licencing

In the year to 9 October 2025, OTSI has:

• Received 60 licence applications

• 12 were granted in full or partially granted

• 3 were refused

• 7 were withdrawn by the applicant

• 1 applicant was informed that no licence was required; and

• 5 were submitted in error.

The majority of licences concerned the planned provision of professional and business services ordinarily prohibited under the Russia (Sanctions) (EU Exit) Regulations 2019. Most of these were submitted via a new application portal on GOV.UK.

Enforcement

In the year to 9 October 2025, OTSI’s Compliance and Enforcement unit received 146 reports or referrals relating to potential breaches of trade sanctions. The majority were submitted by the financial services sector in line with mandatory reporting obligations to report potential breaches of trade sanctions. 16% were reported by sectors to which mandatory reporting obligations do not currently apply.

OTSI did not impose any civil monetary penalties in the reporting period.

Engagement

OTSI said it has met with over 200 stakeholders and handled 210 stakeholder queries. It launched an e-alert platform in March 2025. OTSI said it has worked with partners in international jurisdictions including the US, Europe and the G7.

OTSI provides guidance to businesses in the financial sector. For more information, see our UK guidance pages.