Guidance

Information you must provide in response to a trade sanctions information request

If the Office of Trade Sanctions Implementation (OTSI) asks you for information, you must provide it. If not, you may be committing an offence.

What the Office of Trade Sanctions Implementation (OTSI) can request from you

OTSI, which is part of the Department for Business and Trade (DBT), can request information from you. They can do this to investigate a suspected breach of a prohibition, or a suspected failure to comply with an obligation imposed under sanctions regulations and to help them monitor compliance with, or detect evasion of, trade sanctions.听

OTSI can specify the format you must supply this information in, and the timescale in which you must supply it.听聽

This can include requesting you to provide specific documents.听

They have the legal powers to do this under the .听

If you鈥檙e unsure of your disclosure obligations, you may wish to seek independent legal advice.听

Documents OTSI might ask you to supply

Examples of documents OTSI might ask for include, but are not limited to:聽

  • bank collection聽

  • bill of exchange聽

  • bill of lading聽

  • certificate of origin聽

  • commercial invoice聽

  • danger goods notes聽

  • due diligence report聽

  • electronic transfer evidence聽

  • end use certification聽

  • export cargo shipping instruction聽

  • export licence聽

  • import licence聽

  • letter of credit聽

  • notification to the government that an exception applies to your activities聽

  • packing list聽

  • proof of insurance聽

  • risk assessment聽

  • road consignment (CMR) note聽

  • sale contract聽

  • standard shipping note聽

  • transit accompanying document聽

  • 飞补测产颈濒濒听

If they request documents and you do not have them, you must take reasonable steps to obtain them. You must keep them in your personal possession, or in your control, until you give them to OTSI.听聽

OTSI 尘补测:听

  • take copies of or extracts from the documents聽

  • ask for an explanation of the document from current or past employees or officers聽

They can specify:聽

  • the timescale within which you must supply this information聽

  • the way you must supply it聽

If you fail to comply: committing an information offence

You might be committing an information offence if OTSI requests information from you (in line with their legal powers to do so) and you either:聽

  • refuse, or fail, to comply within the time and manner specified, without providing a reasonable excuse, or if no time has been specified, fail to comply within a reasonable time聽

  • knowingly, or recklessly, give false information, or produce a document containing false information聽

  • delete, destroy, mutilate, deface, conceal or remove any document with intent to evade OTSI鈥檚 investigation聽

  • intentionally obstruct them from obtaining the information聽

Failing to comply with an information request is an offence for which you could be prosecuted. If convicted, you may be made to pay a fine and/or be imprisoned, or it could result in you receiving a civil monetary penalty.听聽

Find out more about civil monetary penalties.听

How OTSI may share your information

OTSI may share information you supply, including sharing with other departments, agencies and international partners, in accordance with the disclosure of information regulation, as set out in the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024, data protection legislation and the DBT Personal information charter.

OTSI recognises that some information may be protected by legal professional privilege. Legally privileged information is exempt from having to be disclosed under the above obligations and requirements, and nothing in the regulations is to be read as requiring you to disclose privileged information.听

Get help

For enquiries about information requests, contact OTSI using .

Updates to this page

Published 12 September 2024
Last updated 10 October 2024 show all updates
  1. This guidance is now in force, so the banner saying it is not yet in force has been removed.

  2. First published.

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