Roundup of evidence presented to Parliament on UK trade sanctions regime

3 March 2026

Roundup of evidence presented to Parliament on UK trade sanctions regimeMistervlad/Shutterstock.com

The UK Parliament’s Business and Trade Sub‑Committee on Economic Security, Arms and Export Controls (BTC) heard evidence on the UK’s trade sanctions regime on 25 February 2025. The transcript of the evidence is here. Witnesses were:

  • Sir Chris Bryant MP – Minister of State for Trade, DBT
  • Anna Deibel‑Jung – Deputy Director, Office of Trade Sanctions Implementation (OTSI), DBT
  • Esther Blythe – Deputy Director for Russia and Belarus Sanctions, FCDO
  • Joanne Cheetham – Deputy Director, Customs Compliance, HMRC

Key points from the evidence:

Russia sanctions regime

  • 99.6% of Russian imports to the UK have stopped. The UK continues to export only pharmaceuticals and foodstuffs to Russia on humanitarian grounds.
  • The Government will introduce sanctions end‑use control legislation requiring licences for goods judged at risk of diversion to Russia.
  • All items on the Common High Priority List (CHPL) are subject to trade sanctions.
  • The Government has identified jurisdictions where diversion risks are higher and advises enhanced due diligence for trade with: Armenia, Kazakhstan, Kyrgyzstan, Uzbekistan, Türkiye, Thailand, Serbia, India, UAE, Vietnam, China, Malaysia.
  • Exporters who knowingly allow goods to be diverted to Russia commit a sanctions offence.

Export control enforcement

  • Increased engagement with high‑risk exporters has led to 46 stopped shipments, and 11 disrupted diversion routes or networks.
  • OTSI has proactively contacted all UK manufacturers of CHPL items to ensure awareness of obligations.

Oil, maritime services and pipelines

  • The UK has sanctioned Transneft, the operator of the Russian oil pipeline network carrying most Russian oil exports.
  • The UK supports EU efforts to implement a full maritime services ban on Russian crude and refined products.
  • The Government intends to ban the import of refined oil of Russian origin processed in third countries, subject to legislation.

Enforcement (OTSI, HMRC, OFSI)

  • OTSI has received 185 potential breach reports. Of these, 5 cases are nearing conclusion, 117 have closed and 57 were referred to HMRC.
  • HMRC has 21 live criminal investigations; see our UK enforcement pages.
  • HMRC is exploring options for greater transparency on compound settlements, including possible legislative change.
Michael O'Kane

Michael is Senior Partner at Peters & Peters Solicitors LLP. He has acted in many of the most high profile and sensitive business crime cases of the last 25 years, at Peters & Peters and as a prosecutor. Michael was called…

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