HMRC publishes details of compound settlements it has reached with businesses as a result of HMRC’s investigations into breaches of strategic export or sanction controls committed under the Customs and Excise Management Act, the Export Control Order or the Sanctions and Anti-Money Laundering Act.

Prior to July 2026, these details were published quarterly by the Export Control Joint Unit, part of the Department for Business, Innovation, Science and Trade, via Notices to Exporters (NTEs).

Non-compliance with the legislation is a serious offence and those who breach the rules may be subject to a range of enforcement actions by HMRC, including large financial penalties or referral for criminal prosecution.

A compound settlement is the means where HMRC may offer to settle out of court for a sum of money. This avoids the need for legal proceedings, saving both the offender and HMRC time and money. HMRC will only offer a compound settlement where it is believed there is sufficient evidence to prosecute.

When deciding if a compound settlement is appropriate and the level of the offer, HMRC’s considerations will include factors such as:

• the seriousness of the alleged offence
• whether fraudulent intent can be proven
• the extent of the efforts to perpetrate the alleged offence
• the offender’s previous history
• the extent to which the offender has co-operated with any investigation
• the level of financial penalties known to have been imposed by courts for similar offences

All of the compound settlements have been paid by the businesses, who have accepted they have committed an offence. In some instances, companies have agreed to be named for their offences. Naming brings transparency and ensures greater consistency with other UK sanctions enforcement bodies such as the Office of Financial Sanctions Implementation (OFSI).