HMRC publishes case study on £1.16m Russia sanctions settlement
HMRC has published a case study on a £1,160,725.67 compound settlement reached in May 2025 with a UK exporter that breached The Russia (Sanctions) (EU Exit) Regulations 2019, SI 2019/855 by making goods available to Russia in contravention of the Russia Sanctions Regulations. Notice to Exporters NTE 2025/18, highlights the risks for UK businesses trading with third countries where Russian companies operate, as sanctions can be breached through indirect supply to Russian-owned entities abroad. HMRC emphasised that ignorance of sanctions is not a defence and urged companies to stay informed through government alerts, review trading relationships, and seek legal advice to ensure compliance. Under the regulations, a ‘person connected with Russia’ includes individuals or entities resident, located, incorporated, or domiciled in Russia, even when operating overseas, broadening the scope of the prohibitions. The ‘making available’ offence applies to various categories of goods and technology under multiple provisions, including those related to restricted, energy-related, luxury, and technology goods, as well as comparable prohibitions concerning non-government controlled Ukrainian territories.