UK Sanctions: OTSI and New Export Regime for Sanctioned Goods as of April 27, 2026

Key Information

Starting April 27, 2026, the UK Office of Trade Sanctions Implementation (OTSI) will manage licenses for the export of sanctioned goods and related services to destinations subject to sanctions. This development was announced by the OTSI on April 9, 2026. Applications will continue to be submitted through the Department for Business and Trade’s (DBT) SPIRE system. Main source: Baker McKenzie Sanctions, April 9, 2026.

Key Points

• From April 27, 2026, OTSI will handle the export licensing of sanctioned goods in the United Kingdom.
• The application procedure remains unchanged via SPIRE, continuing current practice. Reference: OTSI announcement from April 9, 2026.
• Declarants will continue using SPIRE to obtain Standard Individual Export Licences (SIEL), ensuring information sharing with HMRC and Border Force.

Context and Challenges

The current UK sanctions regime involves three bodies within the DBT: the OTSI (for services), the Import Controls and Sanctions team, and the Export Control Joint Unit (ECJU), which has previously handled most sanctioned goods. After April 27, 2026, OTSI will be the single point of contact for sanctioned goods, except in cases of dual regimes (sanctions and strategic export controls), which will remain under ECJU’s jurisdiction.

This development takes place against the backdrop of increasingly complex sanctions regimes and trade flows worldwide. Recent sanctions related to Russian energy (see Marine News Magazine, April 15, 2026), Venezuelan goods (see Seatrade Maritime News, April 15, 2026), and the pressures on Iranian oil routes (CBS News, April 17, 2026), illustrate tighter regulation and greater reliance on national control mechanisms. Centralization aims to clarify responsibility for declarants and improve traceability for sensitive transactions.

Impact on the Profession

Declarants, exporters, freight forwarders, and compliance officers must now classify all export license applications for sanctioned goods under OTSI authority, except in cases of dual controls where ECJU remains responsible. Document flows and license monitoring remain unchanged at this stage, but the profession should monitor new regulatory guidelines and updated responsibilities as per the annexes of the relevant regulatory regimes.

Declarants will also need to distinguish the type of authorization to request (SIEL for goods and related services, separate licenses for stand-alone services via the OTSI portal) and ensure that the license is clearly visible to HMRC and Border Force at customs clearance. Additionally, regular monitoring of SPIRE updates and the list of sanctioned destinations published by the UK government is recommended.

Next Steps

• April 27, 2026: Effective transfer of responsibility to OTSI for sanctioned goods (source: Baker McKenzie Sanctions, April 9, 2026).
• Upcoming publication of updated statutory guidance and new user manuals before this date (OTSI, April 2026).
• Ongoing monitoring of SPIRE and regulatory guidelines for every export declaration to sanctioned destinations.

Au 27 avril 2026, l’OTSI devient l’autorité unique pour délivrer les licences d’exportation de biens sanctionnés au Royaume-Uni.
(As of April 27, 2026, OTSI becomes the sole authority for issuing export licenses for sanctioned goods in the United Kingdom.)

Source: Baker McKenzie Sanctions, 9 avril 2026 - https://sanctionsnews.bakermckenzie.com/uk-office-of-trade-sanctions-implementation-to-expand-licensing-remit-to-include-sanctioned-goods-for-export-to-sanctioned-destinations/