Out-Law on 13th April reported that the recent announcement by the UK’s Export Control Organisation (ECO) of a 6-figure compound penalty for unlicensed exports signifies an increase in both export control enforcement and in the penalties being imposed.  HMRC has recently issued a ‘compound penalty’ of £109,312.50 to a UK exporter for unlicensed exports of military goods controlled by the Export Control Order 2008, is a significant one. HMRC does not generally announce the imposition of compound penalties [although it can impose “compounding with publicity” where felt necessary in the public interest].  The article considers the factors HMRC would take into account when considering whether to prosecute or accept a compounded penalty.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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