The Department for Business and Trade (DBT) and the Office of Trade Sanctions Implementation (OTSI) have published guidance for businesses on sanctions end-use controls, a new licensing requirement for exports to non-sanctioned third countries where the UK government identifies a risk of diversion to sanctioned destinations. The controls apply to goods and related technology under 11 sanctions regimes, including Russia, Iran, Belarus, North Korea, Myanmar, Libya, Somalia, Syria, Venezuela, Zimbabwe and Iran (Nuclear), but exclude items already subject to strategic export controls. Exporters are required to obtain a licence only once they have received written notification from DBT or HMRC of a specific diversion risk. After that point, exporting without a licence constitutes a criminal offence. Applications will be assessed by DBT on a case-by-case basis, taking into account factors such as the nature and potential use of the goods or technology, diversion risks associated with the customer, route or end-user, the exporter's compliance record and due diligence processes and any available intelligence. Non-compliance may result in enforcement action, including the detention or seizure of goods by HMRC at the border, revocation or refusal of existing and future export licences, monetary penalties imposed on a strict liability basis, public naming and criminal prosecution. The guidance also confirms that OTSI does not currently accept advance licence applications, meaning exporters must wait until they receive formal notification before applying.