Overview
Steptoe partner Alex Melia recently authored an article that appeared in Law360, "Sanctions Spotlight: Compliance Insights After OTSI's 1st Year." The article discusses OTSI's first‑year report and what it means for businesses. Launched in 2024, OTSI is the UK's civil trade‑sanctions enforcer, focused on helping companies comply and strengthening sanctions through licensing and investigations. In year one, it issued guidance, examined evasion risks, and processed 60 license applications, approving 43%. It received 146 breach reports – mostly from financial firms – and began multiple investigations while collaborating closely with international partners.
In 2026, OTSI plans to expand outreach beyond London, take on broader export‑sanctions licensing, and increase proactive enforcement using intelligence and cross‑government coordination. Businesses should expect heightened monitoring and consider upgrading their sanctions risk assessments and compliance controls.
Read more at Law360 (subscription may be required).