HMRC imposes another heavy penalty for breach of UK export controls rules

Illumina Cambridge Limited has paid HM Revenue and Customs (HMRC) a compound settlement of just under £7.5 million for offences under the Russia (Sanctions) (EU Exit) Regulations 2019.

This follows a compound settlement for strategic export offences, £6.4 million, imposed in August (see Airbus pays HMRC record fine for breach of Strategic Export Controls).

The latest case was brought to HMRC’s attention following a voluntary disclosure by Illumina, who fully co-operated with the investigation and has undertaken remedial actions, including ceasing all business involving Russia.

HMRC warned: “The case highlights how sanctions breaches can occur when UK businesses are involved in supply chains that result in sanctioned goods being supplied indirectly to Russia (or other countries subject to trade sanctions), even when no goods have been exported from the UK.”

It has reminded traders that, in May 2026, the Government introduced Sanctions End-Use Controls (SEUC). These constitute a new licensing requirement for export to a non-sanctioned third country where the exporter has been informed by the Government that there is a risk of ultimate diversion of the goods or related technology, via that route, to a sanctioned destination.

Guidance on SEUC can be found here.

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