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A record UK export control settlement 10 August 2026 On 30 July 2026, His Majesty’s Revenue and Customs (HMRC) announced that AirbusOperations Limited (Airbus) had paid £6,409,388 to settle multiple breaches of the UK’sstrategic export control regime, a sum it describes as the highest compound settlement it hasreached for offences of this class.1 The published material identifies no unlicensed export and nodiversion of controlled goods. What it records are repeatedfailures to keep the requisite records and registers, togetherwith one breach, of undisclosed character, of an individuallicence. The question for exporters on both sides of thechannel is what administrative noncompliance under an openlicence now costs, and how the decision to disclose voluntarilyis altered once those who settle are named. The breaches On multiple occasions the company failed to keep accuraterecords of transfers of controlled technology as three of itsOGELs required, contrary to Article 29(2)(a) to (g); to keepthe registers those licences required, contrary to Article 29(3)and to keep records as one licence specifically required,engaging Article 29(2)(i). It breached a SIEL condition once.The three licences are not identified, and nothing publishedindicates that a licence was suspended, that an unlicensedexport occurred or that controlled goods reached anunauthorised destination. The offences are those of Article38(1), not Article 34(5), under which knowing involvementin a prohibited activity with intent to evade attracts up to10 years.3The matter concerns record-keeping and licenceadministration rather than evasion, though the nature of theSIEL breach has not been disclosed. Background The framework principally engaged is the Export Control Act2002 and the Export Control Order 2008, with licensing andcompliance sitting with the Export Control Joint Unit (ECJU)and criminal enforcement with HMRC. The bargain underlyingan Open General Export Licence (OGEL) is this: in place of theadvance authorisation a Standard Individual Export Licence(SIEL) requires, the exporter assumes the record-keepingand audit obligations by which the ECJU verifies, after theevent, that the licence has been used within its terms. Thoseobligations sit in Article 29, which requires detailed registers orrecords of each authorised act, capturing the act, the goodsor technology, the dates and quantity, the identities of licenceuser, consignee, supplier and end-user so far as known, andwhatever further information the licence itself requires. Recordsare kept for three years from the end of the relevant calendaryear, four where the licence authorises an act otherwiseprohibited by the Part 4 trade controls and longer where alicence so prescribes, as those covering military technologycommonly do. Breach of a licence condition, or of an Article 29obligation, is an offence under Article 38(1), carrying up to twoyears on indictment and section 152(a) of the Customs andExcise Management Act 1979 permits the commissioners tocompound proceedings, so that a settlement is an alternativeto prosecution rather than a species of civil penalty.2 The fine The sum is without precedent: approximately double the£3,231,762.40 paid in February 2025 for unlicensed exportsof military goods, and approaching the £6,900,587.14 that 22settlements produced across the whole of 2022. Repeatedrecord-keeping failures have therefore attracted a sumcomparable to a full year of enforcement in previous years,notwithstanding the voluntary disclosure, cooperation andremediation of the notice records. HMRC publishes the criteriafor setting a compound sum, among them the type andvalue of the goods and the offender’s previous history, butnot how they are to be calculated.4Neither their weighting,nor the number of transfers concerned nor the nature ofthe technology has been disclosed. The published materialsupports no attribution of the sum to any single factor, and noconclusion confined to any sector. Comparison Character and publicity A compound settlement is not a conviction, and no courtmakes any finding. Airbus is nonetheless recorded as havingadmitted the breaches, and HMRC compounds only wherethe evidence would support a prosecution, the breach wasinadvertent or attributable to weak internal control and theexporter disclosed voluntarily. Until recently the identity ofan exporter accepting a settlement was not published. Thatchanged when HMRC named Petrofac Facilities ManagementLimited over a settlement of £569,157.07 concerning theRussia sanctions regime, and naming will now, accordingto HMRC, form a condition of the offer where appropriate.According to HMRC’s own press release, “Naming thecompany marks a shift in how HMRC handles compoundsettlements in relation to strategic exports.” Groups established in the EU face analogous, thoughnot identical, obligations. Article 27 of Regulation (EU)2021/821 requires registers or records kept for at least fiveyears from the end of the relevant c