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.Ìý
OTSI can specify the format you must supply this information in, and the timescale in which you must supply it.ÌýÂ
This can include requesting you to provide specific documents.Ìý
They have the legal powers to do this under the .Ìý
If you’re unsure of your disclosure obligations, you may wish to seek independent legal advice.Ìý
Documents OTSI might ask you to supply
Examples of documents OTSI might ask for include, but are not limited to:Â
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bank collectionÂ
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bill of exchangeÂ
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bill of ladingÂ
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certificate of originÂ
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commercial invoiceÂ
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danger goods notesÂ
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due diligence reportÂ
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electronic transfer evidenceÂ
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end use certificationÂ
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export cargo shipping instructionÂ
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export licenceÂ
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import licenceÂ
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letter of creditÂ
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notification to the government that an exception applies to your activitiesÂ
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packing listÂ
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proof of insuranceÂ
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risk assessmentÂ
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road consignment (CMR) noteÂ
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sale contractÂ
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standard shipping noteÂ
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transit accompanying documentÂ
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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.ÌýÂ
OTSI ³¾²¹²â:Ìý
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take copies of or extracts from the documentsÂ
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ask for an explanation of the document from current or past employees or officersÂ
They can specify:Â
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the timescale within which you must supply this informationÂ
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the way you must supply itÂ
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:Â
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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 timeÂ
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knowingly, or recklessly, give false information, or produce a document containing false informationÂ
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delete, destroy, mutilate, deface, conceal or remove any document with intent to evade OTSI’s investigationÂ
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intentionally obstruct them from obtaining the informationÂ
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.ÌýÂ
Find out more about civil monetary penalties.Ìý
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.
Legal professional privilege
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.Ìý
Get help
For enquiries about information requests, contact OTSI using .
Updates to this page
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This guidance is now in force, so the banner saying it is not yet in force has been removed.
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First published.