In a letter written from the UK’s HMRC (the body with primary responsibility for the criminal enforcement of trade sanctions) to Parliament’s Treasury Select Committee, HMRC has provided significant information on its recent enforcement efforts.
| Year | Number of investigations opened |
| 2021 | 0 |
| 2022 | 14 (all relating to Russian sanctions) |
| 2023 | 22 (20 relating to Russian sanctions) |
| 2024 | 29 (27 relating to Russian sanctions) |
Of those 65 investigations, HMRC has confirmed that 30 remain live of which 27 relate to Russian sanctions.
The letter tabulates the six fines imposed to date for breaches of the Russian sanctions, and in relation to the largest single fine of £1,000,000 imposed in August 2023 (see our earlier post), the letter notes that this fine relates to “brokering and technical assistance” and not to an actual export.
HMRC’s letter also states that a previously published compound penalty of £1,000 from September 2023 (see our earlier post) was actually for a breach of the UK’s Iran sanctions despite being described at the time as “relating to the attempted export of Dual Use goods”.
HMRC’s letter also states that in October 2024 it referred a case for possible prosecution to the Crown Prosecution Service.