Corporate Crime analysis: The Office of Trade Sanctions Implementation’s (OTSI) Annual Review 2025-2026 reveals some interesting trends, but that are in many ways not surprising. OTSI has not yet taken any enforcement action, but decisions are expected on a number of ‘advanced’ investigations this coming year. Of course, the Russia (Sanctions) (EU Exit) Regulations 2019, SI 2019/855 dominates their outlook and focus, both with regarding to licencing, and investigations and enforcement. Much of their investigative and enforcement work is generated through mandatory reporting (62%), in particular from the financial services industry. Regarding OTSI’s licencing function, 50 of the 51 licence applications related to Russia, however whilst they are approving more licences, they are taking longer to do so. Whilst OTSI has been heavily Russia focused to-date, it is highly likely that the expansion of sanctions on Iran will seek a marked increase in OTSI’s caseload. Written by Liam Lane, Associate at Peters & Peters.