Change description : 2025-05-21 16:54:00: ‘Whistleblowing for trade sanctions’ section added. This section explains that “from 26 June 2025, you will be able to make a whistleblowing disclosure to the Office of Trade Sanctions Implementation (OTSI) about a person or business you think is committing a breach of trade sanctions that are implemented and enforced by OTSI.” [Guidance and regulation]
If you breach trade sanctions, you may face enforcement action, which could include criminal prosecution or a civil monetary penalty.
How to report a suspected breach
How you make a report will depend on which trade sanctions measures you think have been breached, as you’ll need to report them to the correct organisation.
Certain trade sanctions measures are implemented and enforced by the Office of Trade Sanctions Implementation (OTSI), which is part of the Department for Business and Trade (DBT). Most others are enforced by HM Revenue & Customs (HMRC), except the oil price cap (HM Treasury) and internet service measures (Ofcom).
This page explains which trade sanctions breaches you should report to OTSI and which to HMRC. You can then:
use the online service linked from the button on this page to report to OTSI
find out how to report to HMRC
There are specific rules for reporting if you’re a provider of legal or financial services or a money service business.
Who to report to
Report these suspected breaches to the Office of Trade Sanctions Implementation (OTSI)
Use the online service on this page to tell OTSI if you think you, or anyone else, have breached trade sanctions by:
providing or procuring sanctioned services
moving, making available or acquiring sanctioned goods outside the UK
transferring, making available or acquiring sanctioned technology outside the UK
providing ancillary services to the movement, making available or acquisition of sanctioned goods outside the UK
providing ancillary services to the transfer, making available or acquisition of sanctioned technology outside the UK
the provision of ancillary services relating to the import and export of goods and the transfer of technology to, or from, the UK
goods and technology, such as military and dual-use goods and technology, which are subject to strategic export controls
ReportHow report to the Office of Trade Sanctions Implementation (OTSI)
Report yourself or someone else (voluntary disclosure)
If you think you, or someone else, may have breached trade sanctions, you should report it.
If you’re reporting about yourself or your business, your voluntary disclosure may be a mitigating factor in OTSI’s assessment of the case. For example, it may reduce the level of any civil monetary penalty OTSI may impose.
If you’re a provider of legal or financial services (mandatory reporting)
If you’re a provider of legal or financial services (also known as a relevant person), you have a legal obligation to report a suspected breach of the trade sanctions that are enforced by OTSI.
You are a whistleblower if you are a worker and you report certain types of wrongdoing. This will usually be something you have seen at work, but not always. You can read more about whistleblowing for employees.
The wrongdoing you disclose must be in the public interest. This means it must affect others, for example the general public.
From 26 June 2025, you will be able to make a whistleblowing disclosure to OTSI about a person or business you think is committing a breach of trade sanctions that are implemented and enforced by OTSI. If you are not sure who to contact, find out where to make your report.
Report to OTSI using the online service
You cannot currently use this service to report a breach anonymously.
If you’re reporting as a third party and you need to report several unrelated businesses which you’re representing, you must submit a new report for each business.
If you’re unable to use this service, contact OTSI.
What happens next
OTSI will review your report. They may need to get in touch with you for more details before they can decide if there has been a breach.
If your report concerns a breach committed by you, your business, or the business you represent, OTSI will inform you of any action they may take. OTSI cannot give a timescale for this due to the complexity of some cases.
If your report concerns a breach committed by someone else or by another business, OTSI will not inform you of any action they may take due to case confidentiality.
If you have acted, or are acting, as counsel or solicitor for a person or business, any information you provide does not require you to disclose any privileged information in your possession.
Other reporting obligations
Reporting to OTSI is in addition to any other sanctions reporting obligations you may have. These could include reporting to the Office of Financial Sanctions Implementation (OFSI), reporting required by your regulator (if you have one) or submitting Suspicious Activity Reports (SARs) to the National Crime Agency (NCA) under the Proceeds of Crime Act 2002.
Removed some details about reporting to HMRC, as this information is now on the HMRC page linked from this section.
24 January 2025
Extra information added to explain what happens next if your report is about another person or business (not about yourself, your business, or a business you represent).