Russia sanctions represent one of the most significant areas of customs enforcement risk for UK businesses. With penalties reaching into the millions, a closed OFSI list and an evolving enforcement landscape, understanding how UK border controls interact with sanctions compliance has never been more important.

The Legal Framework

The primary legislation governing Russia sanctions in the UK customs context is the Russia (Sanctions) (EU Exit) Regulations 2019, substantially amended since Russia’s invasion of Ukraine in February 2022. These regulations create a comprehensive regime covering trade, financial services, transport and individual designations.

For customs purposes, the key prohibitions relate to the import and export of specified goods, including dual-use items, luxury goods, certain technology and raw materials designated as economically significant to Russia. Every shipment touching these categories must be screened before it moves.

HMRC Enforcement — Compound Penalties

HMRC uses compound settlement as a civil alternative to criminal prosecution for customs offences. In the context of Russia sanctions, the scale of enforcement has grown dramatically since 2022. The largest recorded HMRC compound penalty stands at £1,160,725.67, imposed in May 2025 — a stark demonstration of the financial exposure businesses face from non-compliance.

Compound settlements allow HMRC to recover the value of the offending goods plus a penalty without initiating criminal proceedings. For businesses, this represents a serious risk even in cases of inadvertent error, underscoring the importance of robust due diligence procedures.

The UK Sanctions List — The ONLY Authoritative Source

A critical compliance point: since 28 January 2026, the OFSI consolidated list has been closed. The UK Sanctions List, maintained by the Foreign, Commonwealth and Development Office (FCDO), is now the sole authoritative source for checking whether an individual, entity or vessel is sanctioned under UK law.

Businesses that previously relied on the OFSI list must immediately update their screening processes to use the UK Sanctions List exclusively. Failure to do so creates a fundamental gap in compliance that could expose a business to liability even if the entity screened was not on the OFSI list but is on the UK Sanctions List.

For professional sanctions compliance support, working with advisors who are current with UK Sanctions List updates is essential.

OFSI Penalties — Civil and Criminal Exposure

The Office of Financial Sanctions Implementation (OFSI) administers the financial sanctions regime. For breaches, OFSI’s civil penalty power is significant:

• Up to £2 million, or
• 50% of the total value of the breach (whichever is higher)

In addition to civil penalties, deliberate or knowing violations of financial sanctions can result in criminal prosecution. The courts have demonstrated willingness to impose substantial custodial sentences in serious cases.

Cross-Government Strategy — May 2025

In May 2025, the UK government published a cross-departmental Russia sanctions enforcement strategy, coordinating HMRC, OFSI, the FCDO, Border Force and intelligence agencies. This strategy signals a more integrated and intelligence-led approach to sanctions enforcement, with greater information sharing across departments.

For exporters and freight forwarders, this means that sanctions checks are no longer siloed — a discrepancy flagged by one agency will now be more likely to trigger action by others. Businesses offering export screening services must ensure their processes reflect this joined-up approach.

Practical Steps for Compliance

• Screen every transaction against the UK Sanctions List (not OFSI — it is closed).
• Implement end-use controls for dual-use exports.
• Conduct enhanced due diligence on intermediaries and third-country routing.
• Train staff on Russia sanctions prohibitions and red flags.
• Maintain audit trails for all sanctions screening decisions — minimum 6 years.

Government Source

Full UK sanctions collections and guidance: GOV.UK — UK Sanctions Collections.