His Majesty’s Revenue and Customs, the body empowered to enforce export controls and trade sanctions in the UK, has today published two Notices to Exporters setting out compound penalties in relation to Russian sanctions and export control violations.
The first Notice, in relation to an unnamed company, relates to a penalty of £1,058,781.79 imposed for breaches of the UK’s Russian sanctions regulation.
No information is given as to the nature of the conduct, the value of the goods, or why a criminal prosecution was not brought. There is no mention of a confiscation of the proceeds of crime.
The second Notice relates to export control violations that are not described as breaches of the UK’s sanction. Again no information is given as to the names of the companies, the nature of the violations, or an indication given as to the confiscation of the proceeds of crime.
To quote the Notice:
“The 6 settlements made by UK companies were:
-
- January 2024 – £12,700.00 was paid for a breach of licence conditions in relation to the export of military goods
- February 2024 – £33,822.64 was paid relating to the unlicensed exports of military goods controlled by The Export Control Order 2008
- February 2024 – £971,726.00 was paid relating to the unlicensed exports of military goods controlled by The Export Control Order 2008
- February 2024 – £139,841.85 was paid relating to the unlicensed exports of military goods controlled by The Export Control Order 2008 and dual use goods controlled by Retained Regulation 428/2009
- March 2024 – £92,817.40 was paid relating to the unlicensed exports of military goods controlled by The Export Control Order 2008
- March 2024 – £56,915.27 was paid relating to the unlicensed exports of military goods controlled by The Export Control Order 2008“.