On 29 January 2019, the UK Department for International Trade (DIT) published a notice (the “Notice”, available here) disclosing that, over the last 7 months, HM Revenue & Customs (HMRC) have issued compound penalties ranging between GBP 1,000 and 4,000 to 3 separate UK exporters related to unlicensed exports of dual use goods and export breaches. Further information on these penalties has not been released as none of the cases involved court prosecutions.

Although the Notice relates to the imposition of financial penalties on UK exporters, it is worth bearing in mind that these powers exist alongside prosecutorial enforcement measures. This can be seen in a November 2018 prosecution in which Alexander George (a retired company boss) was handed a 6-month prison sentence, following a HMRC investigation, for trafficking dual-use aircraft parts to Iran in violation of Weapons of Mass Destruction controls (see UK press release accessible here). The penalties referred to in the Notice show continued enforcement of the UK export control regime, and use of the UK Government’s powers in this regard.

For additional information, please contact the author, Alexander Rickets.