Trade sanctions and export restrictions

Trade sanctions and arms embargoes are legal restrictions on exporting to certain countries or entities. The UK independently imposes, updates, and lifts sanctions under the Sanctions and Anti-Money Laundering Act 2018.

Breaching sanctions is a criminal offence carrying unlimited fines, up to 10 years imprisonment, asset seizure, and company director disqualification.

Types of restrictions

Arms embargoes: Complete prohibition on exporting military items, related services, financial services for military goods, and brokering military sales. Covers not just physical goods but also technical assistance and technology transfer.

Trade sanctions: Broader controls on specific goods, technology, or services to particular sectors. Russia sanctions, for example, prohibit advanced technology, dual-use items, aviation components, oil refining equipment, and critical industry inputs.

Trade controls: Even if goods don't pass through the UK, UK persons are prohibited from brokering or arranging sales between third countries when embargoes or sanctions apply.

Catch-all provision and third-country risk

Sanctions can apply to exports to non-sanctioned countries if you know or suspect goods will be diverted to sanctioned destinations or support prohibited activities. This makes end-user due diligence and supply chain transparency essential.

Financial sanctions intersection

Trade sanctions often overlap with financial sanctions. Contact Office of Financial Sanctions Implementation (OFSI) if financial sanctions questions arise alongside export licensing.