On July 20, 2023, HM Government released its annual report on UK strategic export controls, covering the period from January to December 2022. This report offers insights into the UK’s export controls and licensing system, featuring key statistics and noteworthy findings. Here, we summarize some of the report’s key takeaways.
Standard Individual Export Licences (SIELs)
In 2022, the Export Control Joint Unit (ECJU) processed a total of 17,204 Standard Individual Export Licence (SIEL) applications, with 16,664 of them submitted during the reporting period. However, only 62% of these applications were completed within the targeted 20 working days, falling short of the government’s 70% goal. The median processing time for SIELs was 16 working days. The outcomes of these applications are as follows:
- 13,188 licences were issued.
- 423 applications were denied.
- 1,220 applications were withdrawn or halted.
- 2,373 applications did not require a licence.
- 103 licences were revoked.
Individual Professional and Business Services Licences
The UK implemented trade prohibitions related to sector-specific professional and business services under the Russia sanctions regime on July 21, 2022, and December 16, 2022. During this period, the Department for International Trade (DIT) issued 25 Individual Professional and Business Services Licences while rejecting four applications.
Financial Services, Brokering Services, and Technical Assistance Licences
Since 2014, restrictions on brokering services and the provision of financial services and funds have been in place concerning energy-related goods used in the oil and gas industry and other restricted goods and technology, under UK (and previously EU) Russia sanctions. DIT issued the following licences in this category:
- 14 Standard Individual Financial Services Licences related to the supply of energy-related goods.
- 1 Financial Services Licence related to restricted goods and restricted technology.
- 9 Brokering Services Licences connected to the supply of energy-related goods.
- 3 Financial Services, Brokering Services, and Technical Assistance Services licences covering multiple services related to restricted goods and restricted technology.
Enforcement Activity
HM Revenue and Customs (HMRC), Border Force, and UK prosecution authorities collaborated on various enforcement activities, including:
- 177 seizures of strategic goods, where exported goods violated licensing requirements or sanctions and embargoes.
- 157 end-use cases, which prevented non-listed items from being used for illicit military or weapons of mass destruction (WMD) purposes after leaving the UK.
In addition to these actions, HMRC received 317 voluntary disclosures in 2022 and took the following steps:
- Initiated 14 criminal investigations, resulting in one prosecution.
- Reached 22 compound settlements totaling £6,900,587.14, offering alternatives to prosecution in cases involving unlicensed exports of military goods, dual-use goods, and related activities controlled by the Export Control Order 2008.
- Issued 123 warning letters.
- Took no further action in 61 cases.
HMRC played a critical role in enforcing export controls, seizing strategic goods and addressing potential violations through various means, including criminal investigations and settlement agreements. The annual report sheds light on the UK’s efforts to maintain effective export control measures and ensure compliance with sanctions and embargoes.
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