UK Sanctions (Illumia Case) Playbook

🔐 Download the UK Sanctions Extraterritorial Risk SOP, screening templates, and audit checklist to secure overseas supply chains.

About This Note

This playbook gives compliance officers, legal advisers, and trade operations leads an actionable, plug-and-play toolkit for identifying and managing UK sanctions risks in overseas supply chains where goods never physically cross the UK border. Beyond explaining the legal extraterritoriality and "making available" prohibitions highlighted by HMRC’s £7.44m Illumina settlement, it delivers immediate operational utilities, including a 6-step Standard Operating Procedure, a master parameters factsheet, an edge-case FAQ, a pre-and-post-transaction audit checklist, and a standardized intra-group compliance attestation template. Additionally, the detailed 4-step worked example breaks down how to identify a UK nexus, evaluate Regulation 25(1) liability, enforce immediate order blocks across foreign subsidiaries, prevent circumvention, and archive audit-ready evidence to protect your business from civil and criminal penalties.

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