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ARTICLE · 15 SEPTEMBER 2026

Trade Sanctions Developments - OTSI Releases 2025-26 Annual Review

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The UK's Office of Trade Sanctions Implementation has released its Annual Review for 2025-2026, revealing significant insights into licence application processing times, investigation trends, and enforcement activities.

United KingdomGovernment, Public Sector
Davina Given
Davina Given
Tim Potts
Tim Potts
Thomas Jenkins
Thomas Jenkins

On 27 August 2026, the Office of Trade Sanctions Implementation (OTSI), the agency responsible for the implementation and civil enforcement of trade sanctions in the UK, released its Annual Review for 2025-2026. Below, we explore the key issues and themes arising from that publication.

The Annual Review covers OTSI's activities between 1 April 2025 to 21 March 2026. The report provides an interesting perspective on some of the key aspects of OTSIs work and progress through that period, including in areas such as managing licence applications, conducting investigations and enforcement trends.

Licence Applications

  • OTSI received 51 licence applications in the period, mostly from applicants in the food, healthcare and legal services sectors. The vast majority relate to Russia sanctions. This appears to mark a slight slowing down in the number of applications as OTSI previously released figures demonstrating that it had received 60 licence applications in the 12-month period up to 9

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