Title: Navigating OTSI Licence Applications for Sanctioned Activity in Services and Goods

This guidance is aimed at applicants submitting licences to the Office of Trade and Sanctions Intelligence (OTSI) for sanctioned activities that span both services and goods. It provides a clear framework for understanding the requirements, ensuring compliance, and presenting a robust case for permission to engage in the designated activities.

Overview and purpose
OTSI’s licensing regime is designed to regulate activities that fall under sanctions regimes, with an emphasis on preventing illicit trade, human rights abuses, and undermining international security. When an organisation seeks authorisation to engage in sanctioned activity involving both services and goods, a thorough and well-documented application is essential. The purpose of this guidance is to help applicants:

– Understand the scope of authorisations that may be granted for combined service and goods activities.
– Identify the information and evidence needed to demonstrate compliance with applicable sanctions, licensing conditions, and risk controls.
– Present a persuasive case for why the proposed activities will not contribute to sanction violations or other harm.
– Ensure timely processing by aligning submissions with OTSI’s review processes and decision timelines.

Key considerations for applications
1. Define the scope precisely
– Provide a detailed description of the sanctioned activity, including the specific services and goods involved, geographic regions, end-users, and intended end-use.
– Clarify whether the licence covers only outward-facing operations, internal handling, or both, and specify any freight, transfer, or intermediary arrangements.

2. Establish compliance with sanctions regimes
– Demonstrate awareness of the relevant sanctions laws, including any embargoes, prohibitions, and licensing requirements.
– Include a thorough risk assessment identifying potential channels for evasion, diversion, or misuse, and outline mitigation measures.
– Show how the applicant’s controls align with best practices, such as end-user screening, dual-use controls, and monitoring for changes in sanctions designations.

3. Articulate internal governance and controls
– Outline corporate governance structures, roles, and responsibilities related to sanctions compliance.
– Provide policy documents (e.g., sanctions compliance policy, due diligence procedures, and training programmes).
– Describe ongoing monitoring, audits, and mechanisms for reporting and remediating any compliance gaps.

4. Detail end-use and end-user verification
– Present robust end-use and end-user (EU/EU) screening processes, including source of funds, destination verification, and encryption or transfer controls if applicable.
– Include evidence of customer due diligence, risk rating, and ongoing monitoring plans.
– Address potential red flags (e.g., high-risk jurisdictions, politically exposed persons, or opaque ownership structures) and the applicant’s responses.

5. Prove the necessity and proportionality of the licence
– Explain why the sanctioned activity is essential to legitimate business operations and how restricted access would impact operations, markets, or public interests.
– Justify the scope of the licence (geography, products, and services) to balance operational needs with risk minimisation.
– Describe any alternatives or less harmful means considered and why they are not feasible.

6. Provide a robust risk management framework
– Include risk assessment covering operational, reputational, financial, and legal dimensions.
– Outline incident response and remediation plans, including escalation procedures and remediation timelines.
– Demonstrate ongoing risk review mechanisms to adapt to evolving sanctions regimes.

7. Supply practical operational details
– Include timelines for the proposed activities, including procurement, logistics, and service delivery milestones.
– Outline controls over physical goods, data, and technology transfer where applicable.
– Address export control considerations, including classification, licensing, and compliance with international trade rules.

8. Present a clear, auditable evidence trail
– Attach comprehensive documentation: licences, due diligence records, training materials, audit findings, third-party assurances, and any prior compliance certifications.
– Ensure records are organised, easily cross-referenced, and readily available for OTSI review and potential inspections.

8. Prepare for scrutiny and due diligence
– Recognise that the application will be subjected to rigorous due diligence, possibly including supplier and customer verifications, site visits, and audits.
– Expect requests for supplementary information or clarifications; respond promptly with precise, well-structured information.
– Demonstrate a culture of transparency and continuous improvement in sanctions compliance.

9. Plan for post-licence obligations
– Anticipate ongoing reporting requirements, periodic reviews, and mandatory updates to reflect changes in sanctions regimes or business operations.
– Describe training refresh cycles, compliance reviews, and mechanisms for handling licence amendments or revocations.

Document structure and submission tips
– Start with a concise executive summary that encapsulates the purpose, scope, and alignment with sanctions compliance.
– Present the request in logical sections corresponding to the key considerations above, with cross-references to attached evidence.
– Use plain language, avoid jargon where possible, and ensure technical details are accessible to non-specialist review staff without sacrificing accuracy.
– Include a risk-based approach narrative that connects each control to an identified risk.
– Ensure all information is current and verifiable; update dates, names, and identifiers to maintain consistency throughout the submission.
– Attach a comprehensive table of contents and referenced annexes for ease of navigation.

Timeliness and responsiveness
– Adhere to OTSI’s submission deadlines and format requirements.
– If the submission undergoes updates or clarifications, provide a revised version promptly and annotate changes clearly to support efficient processing.
– Maintain open lines of contact with the designated OTSI liaison to address questions or requests for further information swiftly.

Conclusion
Applications for licences to carry out sanctioned activity involving both services and goods require a disciplined, evidence-based approach. By articulating a precise scope, demonstrating rigorous sanctions compliance, and presenting robust governance and risk management measures, applicants improve their prospects of a timely and favourable determination. This guidance is intended to assist organisations in assembling a comprehensive, auditable, and thoughtful licence submission that aligns with OTSI’s mission to uphold international sanctions and safeguard lawful trade.

April 23, 2026 at 12:26PM
OTSI 评估贸易制裁许可申请的方法
本指南适用于向 OTSI 提交的、寻求获取与制裁活动相关的服务及货物许可的申请。

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