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 and Trade

UK strategic export controls (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)

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)

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 (Policing and Crime Act 2017):

Maximum penalties for sanctions offences:

England, Wales, Scotland: Up to 7 years imprisonment and/or unlimited fines (indictment); up to 12 months and/or unlimited fines (summary)
Northern Ireland: Up to 7 years imprisonment and/or unlimited fines (indictment); up to 6 months and/or unlimited fines (summary)
Money laundering linked to sanctions breaches: Up to 14 years imprisonment and/or unlimited fines (Proceeds of Crime Act)

Civil monetary penalties (OFSI):

OFSI can impose strict liability civil penalties regardless of knowledge or reasonable cause to suspect (from 15 June 2022).

Current maximum civil penalty: £1,000,000 or 50% of breach value (whichever is higher)
Proposed maximum civil penalty: £2,000,000 or 100% of breach value (whichever is higher)
Voluntary Disclosure and Co-operation discount: Up to 30%
Early Account Scheme reduction: Up to 20%
Maximum criminal imprisonment: 7 years
Criminal fines: Unlimited
Money laundering imprisonment: Up to 14 years
Penalty consultation period: 22 July 2025 to 13 October 2025
Penalty reforms status: Unified 30% Voluntary Disclosure/Co-operation discount and 20% Early Account Scheme discount now in force

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)

7. Stay compliant when travelling for business

Understand visa requirements, temporary export of equipment, and overseas tax treatment

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 12 months from issue (cannot be extended)
Countries covered: 80+ countries accept ATA Carnets including EU, USA, China, UAE, Australia
Security deposit: 40% of goods value (100-150% for vehicles) - refundable on proper return
Return deadline: Must return completed Carnet to issuing chamber within 30 days of re-entering UK
Processing time: 2-3 weeks (express services available)
Cost range: £150-£400+ depending on goods value

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

7. Stay compliant when travelling for business

8. Meet destination labelling requirements

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