ECJU: “HMRC issued compound penalties up to £54,000 for unlicensed strategic exports”
The ECJU - UK’s Export Control Joint Unit – indicated in a notice to exporters on 10th January 2022 that ‘between March and November 2021, HM Revenue & Customs (HMRC) issued compound penalties relating to unlicensed exports of military goods between £1,000 and £54,000 to 10 UK exporters’
Notables are penalties of £31,355.28 in March 2021 and £54,000.00 in July 2021. Here’s the full list of the 10 settlements.
The notice also states that: ‘HMRC has policy responsibility for enforcing export controls on strategic goods and sanctions and investigating breaches of those controls. Where appropriate, HMRC can use their powers to offer a compound penalty in lieu of a file being prepared and sent to the Crown Prosecution Service.’
So, where do you start to remain compliant. You start by checking whether your goods are required to have a licence. Many companies are not aware of export control regulations implications for them and do not know how to apply for an export license or how to best manage it going forward hence risking strict penalties and fines.
So, if in doubt, start by using the UK’s Export online tool to verify export requirements and also check the UK’s Export Control Joint Unit for their latest notices and further information.
How can we help?
Greater Manchester Chamber of Commerce can provide general advice on your export control query and bespoke consultation on different aspects of UK export controls outlined below:
In-house and bespoke export control compliance training: We can deliver both in-house and virtual training to your team from general compliance to business process and procedure training.
Export Control Audit: Internal Business Audit of your Business Management System regarding Export Control compliance. This can be conducted as part of an annual BMS audit schedule or before an Export Control Joint Unit (ECJU) visit/audit.
Export Control Managed Service: Acting as the focal point for all licensing activities on behalf of the client to ensure all export licensing processes are compliant with internal business processes and export control regulations.
Product Codification: Audit and codification of products against the UK Export Control List. Ensuring correct definition and understanding of licensing requirements. This would normally involve an initial site visit to understand and discuss products.
Licence Application: Acting on your behalf to ensure that appropriate licences are applied for in a timely and accurate manner to ensure smooth export of product(s). These can normally be conducted remotely if a product codification visit has been carried our previously.
SPIRE Set up and Management: Set-up of an HMRC SPIRE Account on your behalf, and if required, ongoing account management ensuring Licences are managed through the HMRC licence management system. This can be conducted remotely without the need for a site visit, depending on customers IT requirements.
ECJU Visit Representation: Representing the client during an ECJU Audit. This would normally only be considered where one or more of the above services have been provided.
Please email firstname.lastname@example.org for more information or if you would like to discuss requirements.