Trade Sanctions

Abstract This chapter provides an overview of trade sanctions under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA), focusing on the Russia (Sanctions) (EU Exit) Regulations 2019 and explaining their distinction from export controls. It explains prohibitions on imports, exports, transfers, and services related to goods and technology, applying extraterritorially to UK persons. Key regulators include the Department for Business and Trade (DBT)’s Office of Trade Sanctions Implementation (OTSI) and Export Control Joint Unit (ECJU), and HM Revenue and Customs (HMRC). The chapter sets out the impact of the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (TASSCER) on civil enforcement. Strict liability civil penalties, criminal offences, available defences, and reporting obligations are detailed, alongside licensing processes (import, export, services) and statutory exceptions. It addresses circumvention, enforcement powers, and compliance challenges amid evolving regimes. Comparative notes on Belarus and Iran regimes highlight sector-specific restrictions.