The Office of Trade Sanctions Implementation (OTSI) has introduced a new service to apply for sanctions licences for the provision of trade services, as part of the OTSI’s new powers. This service replaces the previous process of applying via SPIRE. Applications for goods-related exports sanctions licences remain via SPIRE. Sanctions guidance for Russia and the Republic of Belarus have been updated to reflect this new service.

The Office of Trade Sanctions Implementation (OTSI) has issued two general trade licences allowing UK businesses to support the maritime transport of Russian liquefied natural gas (LNG) to Japan and South Korea under the Russia (Sanctions) (EU Exit) Regulations 2019, SI 2019/855. The licences cover only LNG originating from the Sakhalin-2 Project under supply contracts concluded before 17 June 2025. They authorise shipment from Russia or a third country, related financial services and funds, brokering services and certain legal advisory services to non-UK persons. They aim to protect Japan’s and South Korea’s energy security while those countries reduce their reliance on Russian energy. They do not authorise trade with designated persons, LNG trade under new contracts or other prohibited activities. Users must notify OTSI within 30 calendar days of starting authorised activities and keep records of each act undertaken under the licences. The Secretary of State may vary, revoke or suspend either licence at any time. The licences take effect on 1 January 2027 and expire on 31 March 2028.

The Office of Trade Sanctions Implementation (OTSI) has highlighted its guidance currently available whilst acknowledging the complexities of trade sanctions. OTSI noted that its goal is to enable UK businesses to navigate trade sanctions successfully. In a recent blog post, OTSI explained that its guidance covers the enforcement approach, monetary penalties and appealing them, mandatory reporting, information requests, reporting suspected breaches and applying for trade sanctions licences.

The Office of Trade Sanctions Implementation (OTSI) has published its annual review for 1 April 2025 to 31 March 2026, outlining its work to implement and enforce UK trade sanctions. OTSI received 178 reports or referrals concerning suspected breaches, most relating to the Russia sanctions regime, and closed 104 enforcement cases. It did not impose any civil monetary penalties, although several investigations had reached an advanced stage by the end of the reporting period. OTSI also received 51 licence applications, granted 17 applications and participated in more than 60 stakeholder engagements to help businesses understand and comply with their obligations.

The Office of Trade Sanctions Implementation (OTSI) has published a blog post detailing a case study on suspected breaches of the Russia (Sanctions) (EU Exit) Regulations 2019, SI 2019/855, reported by the UK branch of a multinational bank between April and June 2025. The case concerned several instances of trade in a sanctioned Russian product with a third country, where payments were routed through the UK branch acting as an intermediary. OTSI concluded that no breach had occurred, as the bank's due diligence and account screening procedures successfully identified and prevented the payments from being processed. The blog post sets out key compliance lessons for industry: (1) adopting risk-based due diligence approaches; (2) conducting enhanced due diligence on clients and transactions involving high-risk jurisdictions; (3) understanding UK obligations within multinational corporate structures; (4) developing and maintaining robust internal screening procedures; (5) implementing effective payment safeguards; (6) understanding mandatory reporting requirements; (7) applying financial sector compliance practices across industries; and (8) utilising OTSI's online reporting tool to report potential breaches or near misses.

The Office of Trade Sanctions Implementation (OTSI) has reported on its first year of activity, covering 10 October 2024 to 9 October 2025. OTSI set out how it exercised its civil enforcement powers under the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024, SI 2024/948  and worked alongside HMRC, other government departments and international partners to support the UK’s trade sanctions framework. It emphasised both enforcement and prevention, noting its role in issuing guidance, supporting compliance and administering the licensing process.

The Office of Trade Sanctions Implementation (OTSI) has published guidance outlining requirements for effective trade sanctions breach reporting. The guidance confirms that financial services providers, legal services providers, and money service businesses have legal obligations to report suspected breaches, while others may report voluntarily. It details that useful reports should include contact details, suspected breacher information, supporting documents, and clearly establish UK nexus. The guidance aims to improve report quality following receipt of a large number of breach reports since OTSI's establishment.

The Office of Trade Sanctions Implementations (OTSI) has reported that it has launched a new trade unit that will boost the efficacy of UK's sanctions against Russia. The unit is aimed at ensuring that companies comply with trade sanctions and to penalise those who do not comply with such sanctions. The new unit will collaborate with businesses to provide guidelines and online tools which are easy to use in order to make it easier for businesses to comply with sanctions obligations. Guidance for several sanctions regimes has been updated to reflect the creation of OTSI.

The Office of Trade Sanctions Implementation (OTSI) has announced that from 27 April 2026, it will assume responsibility for licensing sanctioned goods and associated ancillary services for export to sanctioned destinations. This expands OTSI’s current remit, which covers licensing for sanctioned standalone services. Licensing of goods and ancillary services subject to export controls only, or to both strategic export controls and sanctions, will continue to be managed by the Export Control Joint Unit (ECJU). The application process via the Department for Business and Trade’s SPIRE service remains unchanged. OTSI will process applications for sanctioned goods and ancillary services via SPIRE from 27 April 2026 onwards, while those involving goods subject to both sanctions and strategic export controls will continue to be assessed by ECJU. OTSI will publish updated guidance on export sanctions licensing ahead of 27 April 2026 and revise its statutory guidance to clarify which licensing body is responsible for specific prohibitions. Where applicable, OTSI will issue Standard Individual Export Licences via SPIRE to enable immediate provision to HMRC and Border Force. Exporters seeking a sanctions licence for standalone services should continue to use the OTSI online portal.

The Open University (OU) has announced its intention to commission an independent review into OU following the decision earlier this year in the employment tribunal case brought by Professor Joanna Pheonix against OU for harassment and discrimination as a result of expressing her gender-critical beliefs. The review will be lead by the former chief executive of the Office for Students, Universities UK and the Equality Challenge Unit, Professor Dame Nicola Dandridge. The review will start in early May and is expected to take approximately four months to complete.

An oath is a formal promise to tell the truth or perform a duty, made before a court or authorised person, usually invoking a deity or sacred text. It is used in all UK and Irish jurisdictions when giving evidence (for example, as a witness, deponent or interpreter) and when assuming certain public or professional offices (such as judicial or parliamentary oaths).In England and Wales, Scotland and Northern Ireland, oaths in court proceedings are governed principally by the Oaths Act 1978 and related rules of court. In Ireland, oaths are regulated by the Statutory Declarations Act 1938 and court rules. In all four jurisdictions, a person with no religious belief or who objects to taking a religious oath may instead make an affirmation with the same legal effect.A false statement made on oath may constitute perjury or a related offence, with significant criminal penalties. Only specified office‑holders (such as solicitors, commissioners for oaths, notaries public and certain court officials) are authorised to administer oaths. The form of words may vary, but the essential legal feature is the solemn undertaking, creating a binding obligation to tell the truth or faithfully perform the sworn duty.

IP analysis: This case was an appeal of a UK Intellectual Property Office (IPO) decision, where it was held that the trade mark POST MILK GENERATION (‘the Mark’) was invalid for the goods registered in classes 29, 30 and 32. This was on the ground that the Mark offended against section 3(4) of the Trade Marks Act 1994 (TMA 1994), namely, that it used the term ‘milk’ in relation to products which were not ‘mammary secretions’ and so its use was prohibited by Regulation (EU) 1308/2013 (the EU Regulation). Oatly argued that the Hearing Officer erred in their decision, as the EU Regulation only prohibited the use of milk in relation to ‘definitions, designations and sales descriptions’ and not in relation to trade mark use. It submitted that the Mark was an indication of the trade origin of the goods and, as an otherwise valid trade mark, could not be descriptive and so did not fall under the remit of the EU Regulation. Mr Justice Richard Smith allowed the appeal. Written by John Coldham, partner, and Jasmine Lalli, associate, both at Gowling WLG (UK) LLP, who acted for Oatly.