Apply for a licence to carry out sanctioned trade through OTSI

OtherWhat typesa ofsanctions tradelicence licencesfrom OTSI allows you to do 

YouA cannotsanctions uselicence thefrom onlineOTSI serviceallows onyou thisto pagecarry toout applycertain fortrade licencesactivity forthat the:  

• provisionwould ofotherwise sanctionedbe servicesprohibited relatingunder tosanctions goodslegislation, (ancillaryincluding services)the: 

  • exportwould ofotherwise sanctionedbe goods 

  • importprohibited ofunder sanctionedsanctions goods 

  Whatlegislation, aincluding servicesthe: licenceexport, allowstransfer, youand tomaking do 

  Aavailable servicesof licencegoods allowsand youtechnology not subject to providestrategic certainexport tradecontrols

• provision of services thatancillary wouldto otherwisea begood prohibitedor undertechnology, sanctionswhere legislation. 

  Prohibitedthe good or technology the services whichrelate canto beis coverednot bysubject thisto licencestrategic are:  

  export controls

  • provision of professional and business services (underprohibited under the RussiaUK’s sanctions regime) 

    • accounting 

      on Russia

    • advertising 

    • architectural 

    • auditing 

    • businessprovision andof managementother consulting 

    • engineering 

    • ITstandalone consultancyservices and(services design 

    • legalnot advisory 

    • publicrelated relations 

      to a good or technology)

  • energy-relatedThe servicessanctions (underregulations therelating Russiato sanctionsthese regime),prohibited suchactivities asare: 

    • The drilling,Afghanistan well(Sanctions) testing,(EU loggingExit) andRegulations completion2020

    • The servicesCentral orAfrican theRepublic supply(Sanctions) of(EU specialisedExit) floatingRegulations vessels  2020

    • infrastructureThe orCounter-Terrorism tourism-related(International servicesSanctions) to(EU non-government-controlledExit) UkrainianRegulation territories (under the Russia sanctions regime) 2019

    • interceptionThe Democratic orPeople’s monitoringRepublic servicesof (underKorea the(Sanctions) Russia,(EU Exit) Regulations 2019  

    • The Democratic Republic of Belarus,the Iran,Congo Myanmar,(Sanctions) Syria(EU andExit) VenezuelaRegulations sanctions regimes) 2019

    • mining,The manufacturingHaiti or(Sanctions) computerRegulations services2022

    • The Iran (under(Sanctions) Regulations 2023 

    • The DemocraticIran People’s(Sanctions) Republic(Nuclear) of(EU KoreaExit) sanctionsRegulations regime) 2019

    • ships or aircraft-related services (under The DemocraticIraq People’s(Sanctions) Republic(EU ofExit) KoreaRegulations sanctions2020

    • The regime),ISIL such(Da’esh) as leasing and chartering,Al-Qaida crew(United services,Nations shipSanctions) classification(EU services,Exit) bunkeringRegulations or ship supply services 2019

  • The sanctionsLibya regulations(Sanctions) relating(EU toExit) theseRegulations prohibited services are: 2020

    • TheThe Myanmar Democratic(Sanctions) People’sRegulations 2021 

    • The Republic of KoreaBelarus (Sanctions) (EU Exit) Regulations 2019   

    • TheThe Russia Iran (Sanctions) (EU Exit) Regulations 20232019 

    • The MyanmarSomalia (Sanctions) (EU Exit) Regulations 20212020 

    • The RepublicSouth ofSudan Belarus (Sanctions) (EU Exit) Regulations 2019 

    • The RussiaSudan (Sanctions) (EU Exit) regulationsRegulations 2019 

    • The The Syria (Sanctions) (EU Exit) Regulations 2019 

    • The Syria (United Nations Sanctions) (Cultural Property) (EU Exit) Regulations 2020

    • The Venezuela (Sanctions) (EU Exit) Regulations 2019 

    • The Yemen (Sanctions) (EU Exit) (No. 2) Regulations 2020

    • The Zimbabwe (Sanctions) (EU Exit) Regulations 2019

    When you need a servicessanctions licence licence from OTSI

    UK sanctions apply to you if you have a link to the UK, known as a UK nexus. This means:

    • all individuals or businesses within the territory and territorial sea of the UK

    • all UK nationals or UK businesses, wherever they are in the world

    If you have a UK nexus and you want to providecarry servicesout activity which areis prohibited under sanctions regulations, and no general trade licences or exceptions apply to that activity, you will need to apply for a licence. You can find more information on the general trade licences or exceptions which could apply to the activity under the statutory guidance for the relevant sanctions regime.

    When

    OTSI youcan doonly notadvise needon awhether servicesyou require a licence

    If or not if you havesubmit a UKlicence nexus,application. This is because OTSI requires detailed information about the activity you dowish notto needcarry out in order to make this assessment.

    Other types of trade sanctions licences

    You cannot apply to OTSI for a licence to:covering the:  

    • provideexport, servicestransfer, thator aremaking notavailable of goods or technology prohibited byunder sanctionsUK regulations trade sanctions, where the goods or technology are also subject to strategic export controls

    • provideprovision prohibitedof sanctioned services ifrelating theyto goods or technology which are coveredsubject byto anstrategic exceptionexport incontrols sanctions(some regulationsancillary (findservices)

    • import informationof ongoods prohibited exceptionsunder inUK sectiontrade 3sanctions, ofand the relevantprovision statutoryof guidance) related ancillary services

    The statutory guidance for each UK sanctions regime which contains prohibitions on trade activity includes guidance on which licensing body has responsibility for licensing which prohibition. Find out more information about the application process.

    If your business does not have a UK nexus  nexus

    If your business does not have a UK nexus, but it has, for example, employees or consultants who have a UK nexus and will be providingcarrying out the sanctioned servicesactivity on behalf of the business, you’ll need to apply for a licence for these named individuals only. This is covered in the guidance on how applications are assessed.

    Who is covered by a servicessanctions licence licence from OTSI

    A servicessanctions licence from OTSI authorises all named parties (the ‘licensees’) to providecarry out the specified servicesactivity only, for the period stated. stated.

    Once you’re authorised by a licence, you must follow its terms. If you do not, you may be committing a breach of trade sanctions and could be subject to enforcement action.  action.

    You’ll need to select who you want the licence to authorise. A licence authorises either:  either:

    • a business, or businesses, with a UK nexus (the licence will usually cover all employees, members, partners, consultants, contractors, officers and directors) 

    • named individuals with a UK nexus working for a business with no UK nexus (for example, if your business has no UK nexus and therefore cannot be licensed, but you have employees or consultants with a UK nexus who will be providingcarrying out the services) sanctioned activity) 

    • yourself as an individual (for example, if you’re a sole trader and not able to apply under a business with a UK nexus) 

    If you’re naming any individuals on the licence, you should get their consent before you apply. Individuals within the territory and territorial sea of the UK, and UK nationals wherever they are in the world, must comply with UK sanctions, and are personally liable for their compliance.

    A third party, such as a legal adviser, can apply on your behalf. They will need to upload a letter of instruction to the application to show they have your permission to act for you. 

    RenewingWhat ayou licence need to show in your application 

    YouYou’ll mustneed applyto forensure ayour newapplication licencecontains ifall the information which OTSI needs to complete its assessment of the activity you wantwish to: to carry out. More guidance on how OTSI carries out its assessment of trade sanctions licence applications, and the information it requires to do this, is available.

    • renewYou it 

    • addmay orwish removeto detailsprovide thata affectcover letter with your application to enable you to fully describe the coverageactivity you wish to carry out in the level of detail OTSI requires to assess it. Your cover letter should be dated within the licence,last suchmonth. asApplications services,submitted providerswith orout-of-date recipients cover letters will be automatically closed.

    What

    You youmay needwish to showseparate the activities you are seeking a licence for in your application 

    Acover definitionletter ofto yourenable services 

    you to fully describe each one.

    You’llYou needshould not assume that OTSI knows anything about the activity you are wishing to describecarry out. OTSI cannot make assumptions about the specificactivity, servicesand you wantshould totherefore provide anddetailed showinformation howsubmissions theseto alignsupport withOTSI’s one,assessment.

    If you have previously submitted related information to OTSI, the Export Control Joint Unit (ECJU), or more,another government body as part of theanother definitionslicence application, you should resubmit this if you wish OTSI to consider it as part of prohibitedits servicesassessment.

    If inmore sanctionsinformation regulations.is Torequired dofor this,OTSI you’llto needcomplete their assessment

    OTSI may write to referyou closelyduring its assessment to therequest sanctionsadditional regulationsinformation relevantrequired to you. 

    Yourcontinue purposesits forassessment. providingThese theseletters services (includingare specificcalled licensingRequests grounds)

    for Further Information (‘RFIs’).

    You’llIf alsosufficient needdetail tois shownot howprovided providingin your servicesinitial wouldapplication, beOTSI consistentmay withrequest theyou purposesprovide offurther theinformation sanctions.  including:

    These

    • name areof someactivity activitiesdescribed whichin your application
    • name and address of the Departmentprospective licensee
    • name and address of the prospective recipient
    • full description of the activity they wish to provide (including commodity codes for Businessgoods) and Tradewhich (DBT)regulation considersyou areconsider likelyit to be prohibited under
    • reason you consider the purpose of this activity to be consistent with the purposes of the sanctions,sanctions.

    Where andOTSI thereforedoes anot licencereceive maythe belevel grantedof fordetail theseit activities.requires Thesein pre-definedyour activitiesresponses areto knownRFIs, asit licensingmay considerationssend you another RFI containing rephrased or licensingdifferent grounds.questions Ifin you’reorder applyingto underget anythe ofinformation required. OTSI will always explain why it is asking you these grounds,questions.

    If you’llthe needinformation toOTSI considerrequires andis demonstratenot inforthcoming your– applicationeither howbecause provisionof a lack of yourresponse servicesor alignsresponses with one,inadequate detail or more,clarity of– theseOTSI grounds. will close your application. OTSI will always notify you when it does this.

    You

    What you can findexpect allfrom the pre-definedoutcome of OTSI’s assessment

    OTSI has developed a rigorous licensing groundsprocess through which we assess whether to license otherwise prohibited trade on a case-by-case basis, against the applicable licensing considerations and the purposes of the sanctions as set out in legislation. Read more about the relevantprocess statutoryin guidance:our guidance on how applications are assessed.

    • StatutoryOTSI guidancewill onprovide theyou Russiawith a detailed assessment of how UK trade sanctions (sectionapply 3.4) to each activity described in your application to support you to trade compliantly with confidence. For this reason, you may receive multiple outcomes for one licence application. For example, you may be informed that you have been licensed to carry out two activities described in your application, but that you do not require a licence to lawfully undertake a third activity described in your application because it is not prohibited under the UK’s trade sanctions.

    • StatutoryIf guidanceOTSI ondetermines Thethe Republicactivity you wish to provide should be licensed, you will receive an electronic copy of Belarusthe sanctionslicence. (sectionLicences 3.4) for goods or technology which will cross the UK border will be provided to HMRC by OTSI as soon as they are issued.

    • StatutoryIf guidanceyour onapplication thefor Irana sanctionslicence (sectionis 3.4)  refused, you can apply for a licence from OTSI again. Please note that, unless you provide new information as part of this application, you are unlikely to receive a different decision.

    • How long a licence is valid for

      StatutoryIn guidanceyour onapplication, theyou’ll Myanmarneed sanctionsto (sectionexplain 3.3) for how long you require any licence to be granted and why.

    • StatutoryThere guidanceis onno theminimum Syriaduration sanctionsfor (sectionan 3.3) OTSI licence. The standard maximum duration of an OTSI licence is 24 months. However, in very exceptional circumstances, OTSI may consider licensing an activity for longer. You should set out in detail why you are seeking a licence of longer than 24 months if you wish OTSI to consider this.

    • Renewing a licence 

      StatutoryYou guidancemust onapply thefor Venezuelaa sanctionsnew (sectionlicence 3.3) if you want to: 

      • renew it 

      • Statutoryadd guidanceor onremove details that affect the Democraticcoverage People’sof Republicthe licence, such as the nature of Koreathe sanctionsactivity, (sectionthe 3.3) 

        licensees or the recipients 

      ForPlease professionalnote andthat, businessif servicesyou suppliedinclude undernew information as part of your application to renew a licence which may change what activity or who the Russialicence sanctions,covers, OTSI will not consider the application to be a renewal and will consider how these licensingchanges groundsaffect are: its assessment.

      • servicesIf necessaryyour previous licence has lapsed before you apply to renew it, you must explain why you did not apply to renew it sooner. Allowing your previous licence to lapse may suggest that the activity you are seeking a licence for is not essential, and this may affect OTSI’s assessment of whether its purpose is consistent with the deliverypurposes of humanitarianthe assistancesanctions. activity Once a licence has lapsed, the activity must stop. Any continuation of activity without a valid licence could be a criminal offence.

      • servicesBefore submitting a renewal application, applicants may wish to review the [guidance on how OTSI carries out its assessment] (https://www.gov.uk/guidance/how-otsi-assesses-application-for-trade-sanctions-licences#assessment-4-whether-the-purpose-of-the-activity-you-wish-to-carry-out-is-consistent-with-the-purposes-of-the-sanctions) of whether the purpose of the activity you have described in connectionyour application is consistent with the productionpurposes of the sanctions. This section sets out that the purpose of the activity or distributionactivities described in the application are assessed against the stated purposes of food,the providedsanctions thisand the UK’s foreign policy at the time of the assessment, to the extent that it is forrelevant to the benefitoperation of the civiliansanctions population 

      • medicalregime. andOTSI’s pharmaceuticaldeterminations purposes,on providedwhether thisthe purpose of an activity is forconsistent with the benefitpurposes of the civiliansanctions population may change over time.

      • Timescales for assessment

        civilYou societymust not engage in any activities thatprohibited directlyby promotetrade democracy,sanctions humanunless rightsand oruntil theyou rulehave ofa lawvalid inlicence.

        The Russia time taken to assess a licence application is dependent on how many activities a licence is sought for, and how complex they are.

      • servicesOTSI thatmanages arehigh necessaryvolumes of sanctions licence applications. You should allow 6 months minimum for non-Russiana personslicence assessment to divestbe fromcompleted. Russia,OTSI oralways works hard to windconclude downapplications businessas operationssoon as possible and its average time for concluding applications since its launch in Russia

      • servicesOctober 2024 is 82 working days, which areincludes requiredthe time taken by applicants to enablereply activitiesto necessaryrequests for theinformation. urgentPrompt preventionresponses orto mitigationany ofrequests for further information from OTSI will support OTSI to deliver an eventoutcome likelyas soon as possible. OTSI will contact you if it will be unable to haveconclude aits seriousassessment andwithin significantthis impacttimeframe.

        OTSI’s caseload means it cannot provide bespoke updates on humanhow healthyour orapplication safety,is includingprogressing during the safetyassessment ofprocess existingand infrastructureenquiries orseeking thean environment. update will receive a generic response.

      • servicesPlease also note that areOTSI necessarycannot forrespond ensuringto criticalcorrespondence energyfrom supply 

      Thisanyone workswho differentlyis ifnot you’relisted providingas legala advisorycontact services.on Ayour licence mayapplication. beIf grantedan foralternative thecontact provisionwishes ofto legalcorrespond advisorywith servicesOTSI whereabout ayour licensinglicence groundapplication, wouldplease applycontact OTSI in advance to authorise this engagement.

      Data protection and retention

      OTSI consults advisory teams across the activitygovernment, and occasionally counterparts in relationrelevant countries, in order to whichcomplete theits legalassessment advisoryof serviceslicence areapplications. beingYou givenshould (themake ‘relevantOTSI activity’)aware ifwhen thesubmitting relevantinformation activityshould wasyou donehave byany aspecific UKhandling personrequests, and if you are applying or takinghave placeapplied infor thea UK.relevant licence from any other jurisdictions.

      DifferentLicences licensingissued groundsby mayOTSI applyare topublic thedocuments. provisionWhile they are not published online, prospective licensees should be aware of servicesthis. thatLicensees’ names and addresses are notincluded professionalon orthe businesslicence. servicesIf (suchprospective aslicensees interceptionhave orconcerns monitoringabout services,the orinclusion shipsof andtheir aircraft-relatedinformation services).on Findany theselicence ingranted, they should make OTSI aware during the relevantlicence statutoryapplication guidance.process.

      YouAll caninformation stillprovided applyto OTSI as part of your licence application will be retained for a servicesperiod licenceof if15 youryears servicesfrom do notthe alignexpiry withdate of any oflicence issued, or from the pre-defineddate licensingthe grounds.case Instead,was you’llclosed if a licence was not granted.

      Apply for a licence from OTSI

      How you need to showsubmit howa yourlicence servicesapplication areto consistentOTSI withdepends on the purposetype of theactivity sanctions.you Toare doseeking this,a you’lltrade needsanctions licence for.

      How to referapply closelyfor a licence to theprovide Purposessanctioned sectionprofessional inand Partbusiness 1services ofand theother sanctionsstandalone regulationsservices relevantthrough toOTSI’s you.

      Beforeonline youapplication start 

      service

      WhenSince youits providelaunch detailson 10 October 2024, OTSI has been responsible for the trade sanctions licensing of yourstandalone services,services you(services maynot alsorelated needto a good or technology) prohibited under the followingUK’s information:trade sanctions, including professional and business services prohibited under the UK’s sanctions on Russia. These services are:

      • anyprofessional previousand licencebusiness numbers

        services (under the Russia sanctions regime) 
      • accounting 

      • homeadvertising 

      • architectural 
      • auditing 
      • business addressesand ofmanagement named individuals being licensed
        consulting 
      • engineering 

      • documentspublic relations 

      • energy-related services (under the Russia sanctions regime), such as controldrilling, structurewell charts,testing, orlogging detailedand planscompletion forservices divestment or wind-downthe supply of operations
        specialised floating vessels  
      • infrastructure or tourism-related services to non-government-controlled Ukrainian territories (under the Russia sanctions regime) 

      • detailsinterception ofor whomonitoring willservices receive(under the Russia, The Republic of Belarus, Iran, Myanmar, Syria and Venezuela sanctions regimes) 

      • mining, manufacturing or computer services
        (under The Democratic People’s Republic of Korea sanctions regime) 
      • ships or aircraft-related services (under The Democratic People’s Republic of Korea sanctions regime), such as leasing and chartering, crew services, ship classification services, bunkering or ship supply services 

      Apply

      Applications for alicences to provide these services licence 

      should continue to be submitted through OTSI’s online application service using the ‘Start Now’ button below.

      Once OTSI has completed the assessment of your licence application, an outcome letter and any licence issued will be emailed to you.

      You now need a GOV.UK One loginLogin to signuse inOTSI’s toonline thislicence application service. YouYou’ll canbe able to create onea GOV.UK One Login account if you do not already have one. You can also use your GOV.UK One Login to access other government services.

      Please note that, if you are seeking a licence on behalf of multiple UK nationals but you cannot provide their names or addresses, OTSI suggests you follow the ‘business or businesses with a UK nexus’ route on the application service. This will eventually bring you to a page which will allow you to specify that the business is located outside of the UK. On the ‘Business details’ page, please enter the ‘Name of the business’ as ‘UK nationals employed by [name of company], which has no UK nexus’. As set out in the guidance on how applications are assessed, you will need to provide alternative information to the individuals’ names and addresses to ensure OTSI has the information it requires to assess the licence application.

      Start now

      If you’re unable to use this service, service, contact contact OTSI. 

      What

      How happensto next  

      apply for a licence to export, transfer, or make available goods and technology not subject to strategic export controls, and associated ancillary services, through DBT’s SPIRE system

      TheOn licensing27 bodyApril for2026, sanctionedOTSI tradeassumed servicesresponsibility isfor the Officesanctions licensing of Tradethe Sanctionsexport, Implementationtransfer, (OTSI),and partmaking available of goods and technology which are not subject to strategic export controls, and associated ancillary services, from the DepartmentExport Control Joint Unit (ECJU). For now, applications for Businesslicences andto Tradecarry (out this activity should continue to be submitted through DBT).  ’s SPIRE service.

      You’ll need to apply for a Standard Individual Export Licence (SIEL) on SPIRE and following the guidance. Read the general guidance on using SPIRE.

      OTSI’s mayassessment contactprocess youhas ifbeen theydesigned needto furthermirror trade prohibitions in sanctions regulations and more guidance on this assessment process is available. For applications made via SPIRE, please attach a cover letter setting out the information required for OTSI to assesscarry yourout application. its assessment.

      Upon submitting the application, you will be issued with a SPIRE reference number.

      Once OTSI has completed its assessment of your application, you will tellreceive an outcome letter. A licence (if applicable) will be issued via SPIRE. Please note that OTSI licences issued through SPIRE will be in ECJU’s standard format for Standard Individual Export Licences (SIELs) rather that OTSI’s standard licence format. This means you whethermay yournot see an OTSI logo on the licence. OTSI and ECJU both issue trade sanctions licences under the authority of the Secretary of State for Business and Trade, and therefore the licence you receive will still be recognised by HMRC and other inspecting authorities. The accompanying outcome letter, via email, will make clear that the licence has been grantedissued orby denied.OTSI.

      Unfortunately, Theywe cannotare givecurrently a unable timescaleto issue licences for this,applications where licences for some activities have been refused, or do not require a licence, due to the complexitylimitations of the SPIRE system. If you have been licensed to carry out some activity described in your application, but not all of it, you will receive an outcome letter from OTSI via email asking you to submit a further licence application on SPIRE for the activities you have been granted a licence for only, and we will issue the licence as soon as possible. If you are planning to submit a licence application on SPIRE covering a wide range of activity, you may wish to consider splitting this into a number of narrower applications.

      YouWe mustunderstand notthat engagethis is an imperfect solution for applicants and are grateful for your patience while we continue to use SPIRE for these licences. We have opted to use SPIRE for now in anyorder activitiesto prohibitedminimise bydisruption tradefor sanctionsexporters. untilAny acommunications licenceor hasdocumentation beenyou granted. receive from OTSI outside the SPIRE system is legitimate DBT correspondence.

      If you’re unable to use SPIRE, contact ECJU’s helpdesk by emailing exportcontrol.help@businessandtrade.gov.uk.

      Get help 

      If you’re unsure whether this is the right type of trade sanctions licence for your activities, contact OTSI using the enquiry form before submitting your application.