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If you breach trade sanctions, you may face enforcement action, which could include criminal prosecution or a civil monetary penalty.

How to report a suspected breach

How you make a report will depend on which trade sanctions measures you think have been breached, as you鈥檒l need to report them to the correct organisation.听听

Certain trade sanctions measures are implemented and enforced by the Office of Trade Sanctions Implementation (OTSI), which is part of the Department for Business and Trade (DBT). Most others are enforced by HM Revenue and Customs (HMRC), except the oil price cap (HM Treasury) and internet service measures (Ofcom).听

This page explains which trade sanctions breaches you should report to OTSI and which to HMRC. You can then:听

• use the online service linked from the button on this page to report to OTSI听

• find out how to report to HMRC听听

There are specific rules for reporting if you鈥檙e a provider of legal or financial services or a money service business.

Who to report to

Report these suspected breaches to OTSI听

Use the online service on this page to tell OTSI if you think you, or anyone else, have breached trade sanctions by:听听听

• providing or procuring sanctioned services听

• moving, making available or acquiring sanctioned goods outside the UK听

• transferring, making available or acquiring sanctioned technology outside the UK听

• providing ancillary services to the movement, making available or acquisition of sanctioned goods outside the UK听

• providing ancillary services to the transfer, making available or acquisition of sanctioned technology outside the UK

Report these suspected breaches to HMRC

Report breaches of export controls and trade sanctions involving UK customs to HMRC, including those related to:听

• the import or export of goods to, or from, the UK听
• the transfer of technology to, or from, the UK听
• the provision of ancillary services relating to the import and export of goods and the transfer of technology to, or from, the UK听
• goods and technology, such as military and dual-use goods and technology, which are subject to strategic export controls

How to report to OTSI

Report yourself or someone else (voluntary disclosure)

If you think you, or someone else, may have breached trade sanctions, you should report it.听听

If you鈥檙e reporting about yourself or your business, your voluntary disclosure may be a mitigating factor in OTSI鈥檚 assessment of the case. For example, it may reduce the level of any civil monetary penalty OTSI may impose.听

If you鈥檙e a provider of legal or financial services (mandatory reporting)

If you鈥檙e a provider of legal or financial services (also known as a relevant person), you have a legal obligation to report a suspected breach of the trade sanctions that are enforced by OTSI.听听

Read more about reporting obligations for providers of legal or financial services

Whistleblowing for trade sanctions

You are a whistleblower if you are a worker, or ex-worker, and you report certain types of wrongdoing. This will usually be something you鈥檝e seen at work, but not always. You can read more about鈥�whistleblowing for employees.听

The wrongdoing you disclose must be in the public interest. This means it must affect others, for example the general public.听

As a whistleblower you are protected by law. You should not be鈥�treated unfairly or lose your job鈥痓ecause you 鈥榖low the whistle鈥�.听

You can make a whistleblowing report to OTSI about a person or business you think is committing a breach of trade sanctions that are enforced by OTSI. If you are unsure about who to contact, find out鈥�where to make your report.

Reporting as a whistleblower

It helps if you share your name and contact details. OTSI can then contact you if they need more information to progress the investigation.听听

You do not have to give your personal details. However, if OTSI is unable to contact you, it may be more difficult to progress the investigation of your report.听听

Do not send supporting information. You can tell OTSI if you have any when you make your report. If you have given your contact details, OTSI will ask for more information if they need it. We do not encourage whistleblowers to proactively gather further information.

Report to OTSI using the online service

Unless you are reporting as a whistleblower, you cannot use this service to report a breach anonymously.

If you鈥檙e reporting as a third party and you need to report several unrelated businesses which you鈥檙e representing, you must submit a new report for each business.听

If you鈥檙e unable to use this service, contact OTSI.

What happens next

OTSI will review your report. They may need to get in touch with you for more details before they can decide if there has been a breach.听听

If your report concerns a breach committed by you, your business, or the business you represent, OTSI听will inform you of any action they may take. OTSI听cannot give a timescale for this due to the complexity of some cases.听

If your report concerns a breach committed by someone else or by another business, OTSI will not inform you of any action they may take due to case confidentiality.

How OTSI can share information you supply

OTSI may share information you supply, including sharing with other departments, agencies and international partners, in accordance with the , data protection legislation and the .

Legal professional privilege

If you have acted, or are acting, as counsel or solicitor for a person or business, any information you provide does not require you to disclose any privileged information in your possession.

Other reporting obligations

Reporting to OTSI is in addition to any other sanctions reporting obligations you may have. These could include reporting to the Office of Financial Sanctions Implementation (OFSI), reporting required by your regulator (if you have one) or submitting Suspicious Activity Reports (SARs) to the National Crime Agency (NCA) under the Proceeds of Crime Act 2002.听

Get help

Contact OTSI using .