Export compliance is ongoing

This journey covers the ongoing compliance requirements for established exporters: export controls and licensing, sanctions screening, Bribery Act requirements, business travel compliance, and product labelling for overseas markets.

Getting export compliance wrong carries serious consequences - criminal prosecution, unlimited fines, and up to 10 years imprisonment for export control breaches.

1. Know your export control obligations

Understand when licences are required and how the ECJU enforces compliance

Export controls are criminal law

Export controls are not optional. Exporting controlled items without the correct licence is a criminal offence carrying up to 10 years imprisonment and unlimited fines. Review your product portfolio against the Strategic Export Control Lists regularly.

When licence required: Controlled military/dual-use items, goods to sanctioned countries, or if end-use concerns exist
Criminal offence: Exporting without correct licence carries up to 10 years imprisonment and unlimited fines
Processing time (SIEL): Median 16 working days (70% within 20 days, 99% within 60 days)
Application cost: No fee for export licence applications
Regulatory authority: Export Control Joint Unit (ECJU) within Department for Business, Innovation, Science and Trade

UK strategic export controls (opens in a new tab)

Export Control Penalties and Enforcement

Serious consequences of exporting without proper licences - criminal prosecution and civil penalties up to £1.16 million.

Maximum imprisonment: 10 years for criminal conviction
Criminal fines: Unlimited
Civil penalties: Up to 3 times value of goods (record: £1.16 million in 2025)
Enforcement authority: HMRC (criminal) and Export Control Joint Unit (licensing)
Voluntary disclosure benefit: 50-70% penalty reduction if you self-report immediately

Export control breaches are taken extremely seriously. Recent enforcement shows million-pound penalties are increasingly common, with the record £1.16 million civil settlement in 2025 described as a 'wake up call for UK exporters'.

HMRC has primary enforcement responsibility and can offer compound settlements (civil penalties) as alternative to criminal prosecution. The Export Control Joint Unit conducts compliance inspections with statutory rights to review your export records.

ECJU contact for compliance advice (opens in a new tab)

2. Screen transactions for red flags

Compliance is not just about your products - it's about your customers. Enhanced due diligence is required when transactions show warning signs. Document your screening process to demonstrate adequate procedures.

Customer red flags

• Reluctance to provide end-use information or vague responses
• Unfamiliarity with product technical details
• Requests for unusual specifications
• Willingness to pay significantly above market price
• Requests for non-standard shipping or routing
• No established business in relevant sector
• Located in high-risk jurisdiction
• Previous export control violations

Transaction red flags

• Ship to freight forwarder instead of end-user
• Request for labeling inconsistent with end-use
• Requests to falsify documents
• Cash payments or unusual financial arrangements
• Multiple intermediaries without clear reason
• Last-minute destination changes
• Secrecy about final destination

Product red flags

• Orders inconsistent with customer's business
• Quantities inconsistent with stated use
• Equipment beyond customer's technical capacity
• Discussion of controlled items without mentioning licensing

Export control compliance (opens in a new tab)

Due Diligence on Overseas Buyers

Customer due diligence and anti-money laundering requirements under Money Laundering Regulations 2017.

When required: New relationships, transactions of £12,000 or more, suspicious activity, or customer changes
Record retention: 5 years from end of relationship or transaction
Enhanced Due Diligence: Required for Politically Exposed Persons (PEPs) or high-risk third countries
PEP approval: Only senior management can approve new PEP relationships

Standard due diligence verification

Name, photograph on official document (government-issued ID), residential address, and date of birth. Acceptable documents: passports, utility bills, bank statements.

Enhanced due diligence triggers

1. Customer not physically present
2. Politically Exposed Persons (prominent public function holders)
3. High-risk third countries (FATF lists updated monthly)

Money laundering responsibilities (opens in a new tab)

3. Stay compliant with UK sanctions

Understand arms embargoes, trade sanctions, and the serious penalties for breaches

Sanctions change frequently

The UK imposes sanctions on 80+ countries and thousands of individuals. These change frequently - Russia sanctions alone have been updated hundreds of times since 2022. Ongoing monitoring is essential.

UK businesses must comply with sanctions regimes when exporting goods, services, or technology. Sanctions are imposed on specific countries, entities, and individuals. Breaching sanctions is a criminal offence with severe penalties including imprisonment.

Enforcing body: Office of Financial Sanctions Implementation (OFSI) for financial sanctions; ECJU for export controls
Criminal penalty: Up to 7 years imprisonment and/or unlimited fines
Civil penalty: Up to £1 million or 50% of value of breach (whichever is higher)
Strict liability: Some sanctions offences are strict liability - no intent required
Countries under comprehensive sanctions: Russia, Belarus, Iran, North Korea, Syria (among others - check current list)
Consolidated list: OFSI publishes list of all sanctioned individuals and entities
Screening requirement: Must screen customers, suppliers, and transactions against sanctions lists
Reporting requirement: Must report suspected sanctions breaches to OFSI

Types of sanctions:

Financial sanctions: Prohibit making funds or economic resources available to designated persons
Trade sanctions: Prohibit or restrict import/export of specific goods to/from sanctioned countries
Arms embargoes: Prohibit supply of military goods and technology
Travel bans: Prohibit entry or transit through UK

Due diligence requirements:

Before any international transaction, you should: check OFSI consolidated list for designated persons, verify end-use and end-user, check for any sectoral restrictions (e.g., oil and gas, dual-use goods), and obtain licences where required.

UK Sanctions List (opens in a new tab)

OFSI - Office of Financial Sanctions Implementation (opens in a new tab)

UK sanctions screening requirements

How to check who you deal with against the UK Sanctions List, the "reasonable cause to suspect" test and the ownership and control rules.

Financial sanctions freeze the funds and economic resources of designated persons and prohibit dealing with them. To avoid breaching them, businesses check customers, suppliers and other contacts against the UK Sanctions List, which is the only list of UK government sanctions designations.

Reasonable cause to suspect

Reasonable cause to suspect is an objective test. It asks whether there were factual circumstances from which an honest and reasonable person should have inferred knowledge or formed the suspicion.

Ownership and control

A person is treated as owning an entity where they hold, directly or indirectly, more than 50% of its shares or voting rights. Other control tests also apply, such as a right to appoint or remove a majority of the board. Check ownership and control as well as names.

Keeping up with changes

Subscribe to UK sanctions email alerts. If you use a third-party screening provider, ask them how the UK Sanctions List data they supply is kept up to date.

List to screen against: UK Sanctions List
Test for suspicion: Objective: reasonable cause to suspect
Ownership test: More than 50% of shares or voting rights
Updates: UK sanctions email alerts

4. Manage third-country diversion risk

Sanctions apply even when goods never pass through the UK. If you know or suspect goods will be diverted to sanctioned destinations, you cannot proceed. Supply chain transparency is your responsibility.

Criminal penalties

A breach of financial sanctions may be a criminal offence, punishable on conviction by up to 7 years in prison. Where dealing with criminal property is involved, the money laundering offences in sections 327 to 329 of the Proceeds of Crime Act 2002 carry up to 14 years' imprisonment, a fine or both on conviction on indictment.

Civil monetary penalties

HM Treasury, through OFSI, can impose a civil monetary penalty under section 146 of the Policing and Crime Act 2017 if a breach is proven on the balance of probabilities. For breaches on or after 15 June 2022, OFSI does not have to show that the person knew or had reasonable cause to suspect that they were breaching sanctions. Where the value of the funds or economic resources can be estimated, the maximum penalty is the greater of £1,000,000 or 50% of that value. In any other case it is £1,000,000. Officers of a body can also be penalised where the breach took place with their consent or connivance, or resulted from their neglect.

Discounts

OFSI adds any discounts together before applying them to the baseline penalty. They are a voluntary disclosure and co-operation discount of up to 30%, an Early Account Scheme discount of up to 20%, and a settlement discount of 20% (in addition to any other available discount). The settlement discount applies to cases where no notice of intention was issued before 9 February 2026.

Maximum civil penalty: Greater of £1,000,000 or 50% of breach value
Voluntary disclosure and co-operation discount: Up to 30%
Early Account Scheme discount: Up to 20%
Settlement discount: 20%
Maximum prison term for a breach: 7 years
Money laundering offences (indictment): Up to 14 years

Assessing Political and Economic Risk in Export Markets

FCDO Overseas Business Risk assessments covering political issues, corruption, terrorism, and IP protection.

Risk categories: Political/economic, bribery/corruption, human rights, terrorism/security, IP protection
Country coverage: Assessments available for major export markets produced by UK government staff in-country
Transparency International Index: Ranks ~150 countries by perceived corruption levels
FATF lists: High-risk jurisdictions updated monthly for money laundering/terrorism financing

Country-specific examples

India: Ranked 86/180 in Corruption Index. Highest bribery rate in Asia (39%). Requires pro-active risk management through regular due diligence.

China: Wide anti-corruption campaign with severe penalties (up to life imprisonment for offering bribes). IP: Foreign Investment Law prohibits forced tech transfers.

Brazil: Anti-corruption laws based on UK Bribery Act, but recent laws reduced accountability. IP: Must register before market entry.

Overseas Business Risk assessments (opens in a new tab)

5. Prevent bribery and corruption

Build adequate procedures to defend against Section 7 liability

Bribery Act extraterritorial reach

The UK Bribery Act 2010 has extraterritorial reach - it applies to all your overseas activities. Companies face unlimited fines for failing to prevent bribery by associated persons, but you can defend by proving adequate procedures.

Extraterritorial application: Applies to UK businesses and their employees/agents anywhere in the world
Individual penalties: Up to 10 years imprisonment and/or unlimited fines
Corporate penalties: Unlimited fines for companies
Section 7 offence: Corporate failure to prevent bribery by associated persons
Defence: Having 'adequate procedures' to prevent bribery (must prove on balance of probabilities)

Four criminal offences

1. Offering/giving a bribe
2. Requesting/accepting a bribe
3. Bribing foreign public officials
4. Corporate failure to prevent bribery

Six principles of adequate procedures

1. Proportionate procedures
2. Top-level commitment
3. Risk assessment
4. Due diligence on third parties
5. Communication and training
6. Monitoring and review

Bribery Act 2010 guidance (opens in a new tab)

6. Manage agent and intermediary relationships

Using overseas agents and intermediaries is common in export markets, but they create significant compliance risk. You are responsible for their actions under the Bribery Act. Conduct enhanced due diligence on all third parties.

When required: New relationships, transactions of £12,000 or more, suspicious activity, or customer changes
Record retention: 5 years from end of relationship or transaction
Enhanced Due Diligence: Required for Politically Exposed Persons (PEPs) or high-risk third countries
PEP approval: Only senior management can approve new PEP relationships

Standard due diligence verification

Name, photograph on official document (government-issued ID), residential address, and date of birth. Acceptable documents: passports, utility bills, bank statements.

Enhanced due diligence triggers

1. Customer not physically present
2. Politically Exposed Persons (prominent public function holders)
3. High-risk third countries (FATF lists updated monthly)

Money laundering responsibilities (opens in a new tab)

Take samples and equipment abroad temporarily

When you take samples, demonstration kit or exhibition goods out of Great Britain and bring them back, you can avoid paying import duty on them again

Travel compliance matters

International business travel brings its own compliance requirements: visa rules, ATA Carnets for samples, and tax obligations. Getting the business visitor vs work visa distinction wrong leads to deportation and entry bans.

Validity period: Up to 1 year from issue; a replacement carnet can extend it
Countries covered: More than 80, including EU countries, USA, China, UAE and Australia
Security: Set by the issuing chamber
Return deadline: Return to the issuing chamber for discharge before the carnet expires
Processing time: The issuing chamber tells you when your carnet will be ready
Cost: Set by the issuing chamber
Use abroad: No processing or repair, except routine maintenance

Apply for ATA Carnet (opens in a new tab)

8. Meet destination labelling requirements

Research destination-specific requirements before shipping

Manage your export compliance

Export compliance is ongoing

1. Know your export control obligations

3. Stay compliant with UK sanctions

5. Prevent bribery and corruption

Take samples and equipment abroad temporarily

8. Meet destination labelling requirements

Official guidance

Manage your export compliance

Export compliance is ongoing

1. Know your export control obligations

3. Stay compliant with UK sanctions

5. Prevent bribery and corruption

Take samples and equipment abroad temporarily

8. Meet destination labelling requirements

Official guidance

Next steps

Transfer ownership of your business

Close your business partnership

Related journeys

Export controlled goods and dual-use items

Run a tech business

Export to the EU after Brexit

Grow your tech business