ARTICLE
8 November 2024

HMRC Compound Penalties For Russian Sanctions And Export Control Violations Totaling £1.9m

DM
Duane Morris LLP

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HMRC recently issued Notices to Exporters detailing compound penalties: £402,417.75 for unlicensed military exports, £37,743.34 for dual-use goods, and £1,480,785.44 for military goods. Additionally, £58,426.45 was paid for breaches of Russia sanctions.
United Kingdom International Law

The UK's HMRC has issued several "Notices to Exporters" with updates as to recent enforcement activity.

In one Notice, HMRC states that is has agreed three compound penalties with different entities:

  • "August 2024 – £402,417.75 was paid relating to the unlicensed exports of military goods controlled by The Export Control Order 2008
  • August 2024 – £37,743.34 was paid relating to the unlicensed exports of dual-use goods controlled by Retained Regulation 428/2009
  • September 2024 – £1,480,785.44 was paid relating to the unlicensed exports of military goods controlled by The Export Control Order 2008″

As ever with such penalties the nature of the offending is not given, the identity of the offender is not given, and no indication is given as to whether or not the fine includes a confiscation element for the proceeds of the crimes.

In a second Notice, HMRC describes the compound penalty:

"August 2024 – £58,426.45 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019".

Again, no other details or information is provided, although HMRC notes that this is its 6th compound penalty in relation to Russian sanctions totaling £1,363,129.

Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.

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