The UK has introduced a new sanctions end use control, giving the government a new way to intervene where goods or related technology exported from the UK may be diverted to a sanctioned end user, intermediary or jurisdiction. The guidance was published by the Department for Business and Trade and the Office of Trade Sanctions Implementation on 22 April 2026.
The new control is intended to address a gap in the current trade sanctions framework by allowing the government to intervene where goods may be diverted to a sanctioned end user, intermediary or jurisdiction. Until now, where the government suspected that an export to a non-sanctioned third country was at risk of onward diversion, it could warn the exporter, but the decision whether to continue was still largely left with the business. Under the new system, once the government has formally “informed” an exporter that there is a diversion risk, the export cannot proceed unless a licence is obtained.
In other words, this is not a general tightening of all UK exports. It is a targeted new licensing power that can be used where the government believes a specific shipment, route, intermediary or end user presents a credible sanctions diversion risk.
What has changed?
The key change is that the UK now has a sanctions-specific end use control for goods and related technology that are not already covered by the UK’s strategic export controls. The government says the measure is intended to support enforcement against sanctions circumvention and prevent restricted goods from reaching sanctioned destinations indirectly through third countries.
The guidance makes clear that the new control creates a licensing requirement only after the exporter has been informed in writing by the government. Once that happens, exporting the goods or related technology without a licence becomes a criminal offence. Exporters who have not been informed should continue as normal. The control is therefore not a blanket licensing regime.
Which sanctions regimes does it apply to?
According to the government’s guidance, the sanctions end use control currently applies in relation to the following regimes: Republic of Belarus, Democratic People’s Republic of Korea, Iran, Iran (Nuclear), Libya, Myanmar, Russia and non-government-controlled territories of Ukraine, Somalia, Syria, Venezuela and Zimbabwe.
That list is important because it shows this is not a Russia-only measure, even if Russia is likely to be the most immediate practical focus. The guidance says the highest risks currently identified by the government relate to circumvention of the Russia regime, and points businesses to separate UK guidance on countering Russian sanctions evasion.
Why has the UK introduced this now?
The policy intention is clear. The government says sanctioned countries and end users may try to obtain restricted goods through intermediaries in third countries, and that once goods have left the UK there are limited options to stop onward diversion. The new control is meant to intervene earlier, at the point of export, rather than relying only on enforcement after a breach has already happened.
This reflects a wider shift in sanctions enforcement towards anti-circumvention, supply chain scrutiny and evidence of meaningful due diligence. For businesses, the message is that sanctions compliance is no longer only about screening direct counterparties and checking destination countries. It is increasingly about understanding who the real end user is, whether the route makes commercial sense and whether a third-country transaction could still create UK sanctions exposure.
What happens if a business is “informed”?
If a business is informed by the Department for Business and Trade, whether through HMRC’s national clearance hub or directly through OTSI, it will receive a written notice identifying the shipment or transaction and stating that an export licence is required before the goods or technology can be exported. From that point, the business must not proceed unless a licence is granted.
If goods have already been stopped at the border, HMRC may detain them while a licensing decision is made or allow them to be returned to the exporter pending the outcome. The guidance also says OTSI is not currently accepting advance sanctions end use control licence applications, meaning businesses should wait until they are informed before applying.
What should businesses do now?
Even though this is not a blanket licensing requirement, it raises the bar for sanctions due diligence.
Businesses exporting goods or related technology should review whether their current sanctions controls are capable of identifying diversion risk, especially where goods move through third countries, distributors or intermediaries. That means looking beyond simple list screening and asking more practical questions about end use, end users, unusual routes, inconsistent documentation and whether the customer profile matches the goods being shipped. This is particularly relevant for sectors already flagged by the government as higher risk in the Russia context, including aerospace, automotive, microelectronics and heavy machinery.
The new control also reinforces the importance of record keeping. If the government raises questions about a transaction, exporters will need to show what checks they carried out, what warning signs they considered and why they believed the export was compliant. The direction of travel is clear: sanctions compliance now requires stronger judgement, better escalation and more defensible evidence.
A new enforcement tool, not a minor technical tweak
This is a significant development in UK trade sanctions compliance. The sanctions end use control gives the government a more direct way to stop potentially risky exports before they leave the UK, rather than relying only on prosecution after the fact.
For compliance teams, legal teams and exporters, the takeaway is simple. Sanctions risk does not end because a shipment is going to a non-sanctioned country. If there is a realistic risk of onward diversion, the UK now has a mechanism to step in and require a licence.
That makes sanctions due diligence, end-user scrutiny and escalation processes more important than ever.
