What are the UK sanctions end-use controls, and what should exporters do?

Since 13 May 2026, if the government tells you in writing that goods you are exporting, or technology related to them, are or may be intended for a sanctioned country or a person connected with it, you need a licence before you export them. Until you are told, nothing changes: no goods need a licence under this control in advance, and you cannot apply before you are told.

Where it comes from

The Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 (SI 2026/443) added an end-use control to the UK's trade sanctions regimes, for example regulation 55A of the Russia (Sanctions) (EU Exit) Regulations 2019. GOV.UK's guidance for businesses (22 April 2026) lists the regimes it covers: Belarus, North Korea, Iran, Iran (nuclear), Libya, Myanmar, Russia and the non-government-controlled territories of Ukraine, Somalia, Syria, Venezuela and Zimbabwe.

What it covers

Goods and related technology that are not already controlled as military or dual-use items (not in Schedule 2 to the Export Control Order 2008 or Annex 1 of the Dual-Use Regulation), going to a country that is not itself sanctioned, where the government sees a risk that they will be passed on. It adds to the existing ban on making restricted goods available to a sanctioned destination directly or indirectly, which still applies.

Being informed

The Department for Business and Trade, through the Office of Trade Sanctions Implementation (OTSI) or HMRC's National Clearance Hub, sends a written notice that names the shipment or transaction and says a licence is needed. From then on, exporting those goods without a licence is a criminal offence. HMRC may hold goods already at the border, or let them go back to you, while a licence decision is made. The notice explains how to apply and what evidence helps.

What OTSI looks at

The goods and their possible uses; the risk from the customer, the route and the end user; your compliance history and your due diligence; and other information the government holds. A licence is granted if you can show the goods are not ultimately going to a sanctioned destination. If it is refused, the goods cannot go to that end user or by that route.

What to keep

The control does not change record keeping, but GOV.UK's guidance says you may be asked for your due diligence when informed, and a licence depends on it. For each shipment, keep who the buyer, consignee and end user are, how you checked them against the sanctions lists, where the goods are going and through whom, and what you did about any warning signs. GOV.UK's guidance on countering Russian sanctions evasion lists the goods and routes it sees as highest risk, and the Common High Priority List names the items most sought for Russia's weapons.

Penalties

Exporting after being informed, without a licence, can lead to goods being detained or seized, export licences revoked or refused, a monetary penalty (in some cases on a strict liability basis, even if you did not know), being named publicly, and criminal prosecution.

How Certaby helps

Certaby's shipment check screens the buyer, consignee, end user and anyone in between against the UK, UN, EU and US lists, adds what GOV.UK lists for the destination, and keeps one dated record of the shipment with your reference and licence for 7 years. One check for each party screened, £1.49 each; the destination check is free. It is a screening record, not a licensing decision. This guide explains the rules; it is not legal advice.

Source: GOV.UK, Sanctions End-Use Controls: guidance for businesses (22 April 2026)

Last updated 13 October 2026.