UK Publishes Guidance on Sanctions End-Use Controls

Posted by Nathan Taylor on 5/1/26 5:00 PM

In an update published on April 22, 2026, the government of the United Kingdom (UK) provided non-legal guidance for UK businesses that may be affected by Sanctions End-Use Controls (SEUC).

SEUC introduce a targeted licensing requirement for exports to non-sanctioned third countries where the exporter has been informed by the UK government that there is a high risk of diversion to a sanctioned destination or person. The measure applies only to goods (and related export technology) that are not already subject to UK strategic export controls (e.g., military or dual-use lists, WMD controls, or Military End-Use Controls). SEUC are intended to strengthen the prevention of sanctions circumvention by enabling the government to require a licence before a specific export proceeds, rather than relying on post-export enforcement.

A licensing obligation arises only after an exporter is formally “informed” in writing. Exporting the specified goods or technology without a licence after being informed is a criminal offence. When informed, exporters should pause the in-scope shipment or transaction, follow the instructions for applying for a licence, and retain appropriate records and evidence to support the assessment of diversion risk. Border action may include detention of goods pending a licensing decision or allowing goods to be returned while a licence application is considered.

The SEUC guidance can be found here:
https://www.gov.uk/government/publications/sanctions-end-use-controls-guidance-for-businesses/sanctions-end-use-controls-guidance-for-businesses

 

Topics: UK

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