ARTICLE
22 January 2025

HMRC Unaware Of How Many Sanctions Investigations It Is Currently Conducting

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Duane Morris LLP

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Duane Morris LLP, a law firm with more than 900 attorneys in offices across the United States and internationally, is asked by a broad array of clients to provide innovative solutions to today's legal and business challenges.
Sky News in the UK has made a Freedom of Information Request to the UK's primary trade sanctions enforcement body, His Majesty's Revenue and Customs (HMRC), asking for the "number of cases you are currently investigating".
United Kingdom International Law

Sky News in the UK has made a Freedom of Information Request to the UK's primary trade sanctions enforcement body, His Majesty's Revenue and Customs (HMRC), asking for the "number of cases you are currently investigating".

See the Sky News piece here (including some comments from Mark Handley of this blog).

HMRC has responded (available here and with thanks to Sky News for providing a copy).

It has said that "the number of current investigations ... is not centrally recorded. To determine how many investigations are within scope of your request would require a manual search of a significant number of records, held by different business areas".

Sky News also asked about the identities of the entities or individuals which have received the six compound penalties for breaches of the UK's Russian sanctions.

In line with HMRC policy this information was not disclosed because "HMRC do not consider that disclosing the company name would drive compliance, promote voluntary disclosure or be proportionate".

While this has long been HMRC's policy, the stance of OFSI and the new Office of Trade Sanctions Implementation is that they will each name the companies subjected to fines.

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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