Beyond the Sanctions List: the UK’s New End-Use Controls Explained

The UK has added a new layer to its sanctions enforcement framework to strengthen its trade sanctions regime. Known as Sanctions End-Use Controls (SEUC), the measures come into force on 13 May 2026 and expand the government’s ability to intervene where goods are at risk of being redirected to sanctioned destinations — even when the initial transaction appears lawful.

The new regime reflects a growing policy focus on tackling sanctions circumvention, particularly where goods are routed through third countries before reaching sanctioned destinations.

What are Sanctions End-Use Controls?

SEUCs give UK regulators the power to require an export licence for exports to non-sanctioned third countries where the exporter has been informed that there is a risk that goods or related technology could ultimately be diverted to a sanctioned destination or person through that route. The SEUC provisions build on current “making available” prohibitions, which make it an offence to make available, directly or indirectly, restricted goods or technology to a sanctioned destination.

The controls are triggered not by the exporter’s own assessment, but by formal notification from the UK Government. Once a business is informed that a particular export presents a diversion risk, that transaction becomes subject to a licensing requirement. Proceeding without a licence after notification exposes the exporter to sanctions enforcement action.

The controls generally apply to goods and related technology that are not otherwise subject to existing strategic export controls (for example, military and dual-use goods or technology, or the UK’s weapons of mass destruction or military end-use controls).

Scope of the new measures

The SEUC framework applies across a wide range of UK sanctions regimes where restrictions extend beyond arms embargoes (where military end-use controls already apply), including those relating to Russia, Belarus, Iran, North Korea, Syria and others.

How the controls work in practice

The regime is selective rather than universal and operates on a case by case basis. The requirement to obtain a licence under the new regime only applies where the exporter (or freight forwarder) receives a written notice from the Department for Business and Trade (either through HMRC’s national clearance hub or through direct contact from the Office of Trade Sanctions Implementation (OTSI)) specifying that a particular shipment or transaction is at risk of diversion to a sanctioned end user, intermediary or jurisdiction. 

Consequences of non compliance

Exporting without a licence after receiving notice of a diversion risk is a breach of UK sanctions and a criminal offence. HMRC may detain the goods at the border pending a licensing decision or return them to the exporter. Those in breach could face criminal investigation and potential prosecution. Penalties include criminal fines and/ or imprisonment for individuals, or civil penalties.  

Failure to comply can also result in:

• Licence refusal or revocation of existing licences   
• Being publicly named under OTSI’s powers of disclosure  

Practical steps for businesses

SEUCs extend compliance obligations to transactions with no immediate sanctions nexus and enable authorities to act on suspected future diversion risk. Increased scrutiny of supply chains and intermediary jurisdictions is inevitable, which for many businesses will mean that compliance can no longer rely solely on list based screening. Instead, there is a growing expectation to understand the full context of a transaction, including its commercial rationale and ultimate destination.

Authorities will look closely at what a business knew, or reasonably should have known, about the end use, end user, and trade route. This places greater weight on documented due diligence, internal escalation processes, and decision making records.

Considering the new controls, it is important to understand any diversion risks that could apply to your business and take action now, including:

• Reviewing export controls and sanctions compliance frameworks
• Enhancing due diligence on customers, intermediaries, and routes
• Training relevant teams on how to respond to an informing notice
• Ensuring systems can support rapid licence applications and record keeping
• Identifying higher risk jurisdictions and trade routes 

Conclusion

Whilst the SEUC regime does not impose universal licensing requirements, it gives UK regulators greater discretion to intervene where transactions raise strategic or reputational concerns. This places greater emphasis on understanding the whole transaction, rather than just focussing on technical compliance. 
Businesses should be confident that they understand where diversion risk can arise, that any decisions can be explained and defended, and that they can respond quickly to regulatory attention. Organisations that understand their trade flows, intermediaries and routes — and can evidence that understanding — will be best placed to manage the increased scrutiny these controls bring.

Get in touch with our corporate crime team if you would like to know more or need support with sanctions and export compliance. 

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