Goods exporters face stringent requirements under new compliance measures
New sanctions regulations are set to introduce government powers to impose licensing requirements on certain exports. Faced with the risk of exports being halted at short notice and harsh penalties for non-compliance, now is the time for businesses to put plans in place to keep things running smoothly.
Contributor: Saleema Brohi
What is changing?
On 13 May 2026, the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations will come into force.
Amongst the most notable changes, the regulations are set to introduce a new Sanctions End-Use Control compliance mechanism – which will give the government the power to impose a targeted licence requirement on exports where it identifies that the goods or technology might be diverted to a sanctioned destination or end-user, even where the items are not otherwise subject to export controls. Once the exporting business has been formally notified, it must not export, transfer, or make goods available without a licence. Doing so is a sanctions breach – which, under most UK sanction regimes, would constitute a criminal offence, but could also expose the business to civil monetary penalties and enforcement action.
Alongside the introduction of Sanctions End-Use Controls, the regulations also make a series of technical amendments across country-specific regimes including updated monetary thresholds, the removal of certain penalty-related provisions, and the introduction of a new flexibility to allow notices to be issued electronically.
Taken together, the changes reflect a broader shift in UK sanctions policy towards pre-emptive, intelligence-led intervention – enabling regulators to act before goods leave the UK, and before
any breach has occurred. The changes also signal a more assertive enforcement posture as the UK aligns itself with the approaches adopted by the EU and US (which focus heavily on diversion risk, particularly in relation to Russia, Iran and other high-risk jurisdictions).
How could the changes affect your business?
The introduction of Sanctions End-Use Controls will have practical implications for any business involving the export of goods or technology – even when those items are not normally considered high-risk.
Significantly, exporters may now be required to obtain a licence for goods which previously fell outside the scope of the export controls regime. This requirement can occur at short notice and, once notified, businesses must immediately halt the export or transfer until a licence is granted, potentially leading to operational delays, supply chain disruption and the need to renegotiate delivery timelines with customers.
The changes also heighten the compliance expectations faced by businesses. Regulators are likely to expect more robust due diligence on end-users, intermediaries and supply-chain routes, and you may encounter more questions from banks, insurers and logistics providers who will also be adjusting their own risk assessments in light of the changes.
The ability to issue notices electronically could also result in you receiving notices more swiftly, underscoring the importance of ensuring that your internal processes allow such notices to be identified and escalated promptly.
What steps can you take to prepare?
You should review and strengthen your sanctions and export-control compliance policies, with a particular focus on diversion risk-assessment. This includes updating due-diligence procedures, screening processes and contractual protections to ensure that end-use and end-user information is verified and documented. You should also review your supply chains to identify transactions that could attract regulator attention and consider whether additional licensing advice is appropriate for higher-risk exports.
You should also review your internal escalation routes to ensure that any Sanctions End-Use Controls notifications are flagged and escalated promptly. Staff involved in sales, logistics and compliance should receive updated training on Sanctions End-Use Controls to ensure that organisations can respond quickly if necessary.
Key takeaways
1. Review your sanctions and export-control compliance policies, due diligence processes, and internal escalation routes.
2. Review your supply chains to identify any regular transactions which could fall within the scope of the regulations.
3. Implement training for your staff covering the new Sanctions End-Use Controls.
Please be advised that this is an update which we think may be of general interest to our wider client base. The insights are not intended to be exhaustive or targeted at specific sectors as such, and whilst we naturally take every care in putting our articles together, they should not be considered a substitute for obtaining proper legal advice on key issues which your business may face.