OTSI Publishes Guidance on Best Practices for Trade Sanctions Breach Reporting

On December 16, 2025, the Office of Trade Sanctions Implementation (“OTSI”) published a blog post outlining its expectations when businesses report suspected breaches of UK trade sanctions relating to sanctioned services and the movement of sanctioned items overseas.  In addition to providing practical assistance to reporters, the guidance also offers insight into OTSI’s enforcement approach and how OTSI seeks to use breach reports as both an intelligence gathering and a compliance tool.  Businesses should familiarize themselves with the guidance and ensure that they take OTSI’s recommendations into account when preparing mandatory or voluntary reports of suspected breaches for submission to OTSI.

Why Breach Reporting Matters

OTSI uses the reports of suspected trade sanctions breaches that it receives for various purposes.  First, to build up a picture of potential sanctions breaches in respect of which OTSI may decide to take enforcement action, as well as to identify sanctions evasion typologies and gain an understanding of wider patterns of behaviour impacting trade sanctions risk in particular sectors.  Second, even when a report does not result in an investigation or enforcement action, OTSI looks to make use of reports that identify “near misses” as a tool to offer guidance to businesses seeking to strengthen their trade sanctions compliance efforts.  

OTSI’s Assessment of Suspected Breaches

OTSI investigates and carefully assesses the reports of suspected breaches it receives.  This typically involves developing a holistic understanding of the circumstances surrounding the reported conduct and, in particular, ascertaining:

• when the activity took place;
• who the involved parties are; and
• the nature of the specific good or service provided.

All reports to OTSI should include the contact details of the individual or organisation submitting the report (i.e., name and email address), details of the person suspected to have breached UK trade sanctions (i.e., the name and address of the business or individual), and the details of any other parties involved in the reported activity (i.e., the name and contact details (if known)), and any available supporting documentation relating to the situation being reported (e.g., contracts, emails, etc.). 

Best Practice for Trade Sanctions Breach Reporting

OTSI has outlined in the guidance a number of features of useful suspected breach reports, as follows:

1. Presence of a UK Nexus - Reports should clearly set out how the reported conduct is connected to the UK.  For example, the conduct may have happened in the UK or have involved a UK company or UK person overseas.  While OTSI generally does not require information that lacks a clear connection to the UK to be reported, where the presence of a UK nexus is uncertain OTSI would prefer to receive a report than not.
2. Clarity and Conciseness – Reports should explain what happened in the reporter’s own words.  OTSI prefers reports to contain “simple, honest details” in plain English.
3. Identify the Relevant Sanctions Prohibition(s) – If the reporter knows which sanctions prohibition(s) may have been breached they should include this information in the report.
4. Coordinated Reporting – If the reporter has informed (or intends to inform) other public bodies this should be mentioned in the OTSI report.
5. Provide Supporting Documents – When available and possible, supporting documentation should be provided to evidence the points made in the suspected breach report. 

Following these recommendations can significantly reduce follow-up requests from OTSI to clarify information or request supporting documentation.

Conclusion

Reports of suspected breaches, whether made voluntarily by persons that suspect they have breached trade sanctions, by relevant firms subject to mandatory reporting obligations, or by others, play an increasingly important role in the identification of violations and development of enforcement cases.  Businesses that are required to comply with UK trade sanctions should review the new OTSI guidance and, where necessary, consider incorporating the best practice recommendations into their own processes for reporting potential sanctions breaches.  For more information on these developments and their impact, please contact the authors of this post, Alexandra Melia or Elliot Letts, in Steptoe’s Economic Sanctions team in London.