Trade Sanctions Developments - OTSI Releases 2025-26 Annual Review

On 27 August 2026, the Office of Trade Sanctions Implementation (OTSI), the agency responsible for the implementation and civil enforcement of trade sanctions in the UK, released its Annual Review for 2025-2026. Below, we explore the key issues and themes arising from that publication.

The Annual Review covers OTSI's activities between 1 April 2025 to 21 March 2026. The report provides an interesting perspective on some of the key aspects of OTSIs work and progress through that period, including in areas such as managing licence applications, conducting investigations and enforcement trends.

Licence Applications

• OTSI received 51 licence applications in the period, mostly from applicants in the food, healthcare and legal services sectors. The vast majority relate to Russia sanctions. This appears to mark a slight slowing down in the number of applications as OTSI previously released figures demonstrating that it had received 60 licence applications in the 12-month period up to 9 October 2025.
• The average time taken for OTSI to determine a licence application is now 96 working days (up from an average of 82 working days in October 2025). This equates to over four months before the average application is determined.

Investigations and Enforcement

• No precise figure is provided for the number of live investigations being carried out by OTSI, but the report indicates that the agency received 178 reports in the period and closed 104 actions, suggesting that there are in the region of 70 ongoing cases.
• The vast majority of investigations have been driven by reports made to OTSI, with only 6% of new cases being proactively initiated by OTSI's intelligence function.
• Of those reports, over 60% have been made pursuant to mandatory reporting obligations in the financial services sector.
• Russia remains the dominant focus of investigation and enforcement activity with 88% of reports received relating to the Russia sanctions regimes.
• OTSI has not taken any enforcement action with respect to any of its cases in the period, although 40 cases have been referred to HMRC for consideration of criminal enforcement as they relate to potential breaches that predate OTSI's enforcement powers.

Read the full report here: Office of Trade Sanctions Implementation Annual Review 2025-2026