Sanctions Tracker: UK Trade Sanctions Focus

The final sanctions tracker of 2025 focuses on trade sanctions enforcement and guidance in the first year of OTSI. We also report on a further round of significant financial sanctions designations.

One year of the Office of Trade Sanctions Implementation: OTSI publishes inaugural annual update

On 4 December 2025, the Office of Trade Sanctions Implementation (OTSI), part of the Department for Business and Trade, published its first annual update covering the period 10 October 2024 to 9 October 2025. The update outlines OTSI's licensing and enforcement activity in year one and sets out priorities for 2026.

• OTSI received 146 reports of potential trade sanctions breaches in its first year. While the bulk of those reports came from the financial services sector, 16% came from sectors not subject to mandatory reporting obligations. While no civil monetary penalties have yet been imposed, OTSI confirms several investigations are underway. Referrals have also been