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UK Export Control and Sanctions Symposium 2026

Economic security centre stage, end-use and end-user the key takeaways

On 14th October the Export Control Joint Unit (ECJU), the UK government unit responsible for administration of the export control system, hosted the annual Export Control and Sanctions Symposium. Delegates from business, industry and academia came together in London to hear updates on policy and regulation from government departments and to participate in workshops on a variety of relevant subjects. This year’s workshop topics included the application of military end-use controls to frontier technologies, export control and sanctions enforcement, how the Foreign Commonwealth and Development Office applies export licensing criteria and US export controls and sanctions. For the first time this year, the Higher Education Research Security Association (HERSA) also held a workshop focused on collaboration, compliance and research security in the academic context. 

Responsible trade in a contested world 

The overarching narrative spanning this year’s symposium, ‘responsible trade in a contested world’, echoes some of the same realities identified in a recent post on this blog (‘Working together to navigate the grey-zone’ Clear Cogent Solutions blog, 2 October). Intensifying strategic competition between states is accompanied and amplified by rapid and unpredictable technological development, which in itself drives further competition. Around the world, there are numerous flashpoints where state and non-state actors are driving violent, deep-rooted conflicts in pursuit of myriad competing interests. Plenary speakers presented a stark picture of a security environment that continues to be shaped by the war in Ukraine, instability and conflict in the Middle East and the rapid development of emerging technologies. 

New controls, clearer government expectations

Against this backdrop, messaging from government emphasised the importance of protecting UK interests and enabling safe exports and trade to flourish. In pursuit of those aims, the past year saw the introduction of a Sanctions End-use Control (SEUC) regime (Sanctions End-Use Controls: guidance for businesses: https://www.gov.uk/government/publications/sanctions-end-use-controls-guidance-for-businesses/sanctions-end-use-controls-guidance-for-businesses), which gives government new powers to impose licensing requirements on exports of goods and technologies at risk of breaching UK sanctions.

 
Updated and expanded guidance on the application of Military End-use Controls (MEUCs) was also published (Military end-use controls: https://www.gov.uk/guidance/military-end-use-controls), featuring greater emphasis on context of end-use controls, and on the practicalities of navigating the regime.

 
It is significant that both the new SEUC regime and the updated MEUC guidance go further than has previously been the case in articulating government expectations when it comes to due diligence. The responsibility of exporters to assess for themselves the risk that their exports could be diverted to undesirable or sanctioned end uses or end users underpins both, as does the expectation that organisations will develop an appropriate set of safeguards tailored to their own particular circumstances.

Helpfully, the updated MEUC guidance also provides more detail around how to actually identify and mitigate those risks, including links to gov.uk guidance on a range of related topics such as countering sanctions evasion. Government priorities for the year ahead also include a commitment to support exporters in their due diligence checks, to make systems and requirements easy to understand and to make sure that exporters understand what is required of them.

Economic security to the fore

The UK’s approach to economic security was also front and centre. Although arguably a nebulous concept (there is no published definition or strategy), the UK government’s framing of economic security involves precautionary action across seven key risk domains that are already well known to research security practitioners. The seven domains, investment security, IP security, management of partnership risk, physical and personnel security, cybersecurity, supply chain resilience and management of geopolitical instability are all concepts that have become increasingly relevant in the research security space over recent years.

Government action on implementation focuses on a collaborative approach aimed at supporting exporters as they navigate the challenges of a fast changing and turbulent world. The approach rests on a model articulated through three ‘P’s: 

Partner, in terms of government partnership with industry and academia (and with partners internationally);

Protect, in terms of protecting UK interests through the implementation and maintenance of an economic security toolkit (export controls, sanctions and the National Security and Investment Act are integral to this architecture); and

Promote, in pursuit of an overall aim to promote an open, competitive economy that attracts investment and allows businesses to thrive, while at the same time minimising vulnerabilities to bad actor threats.

In terms of how the theory translates into practice, government initiatives designed to support the UK’s economic security are beginning to take shape. The Economic Security Advisory Service (Economic Security Advisory Service (ESAS): https://www.business.gov.uk/campaign/economic-security-advisory-service/?lang=en-gb), currently operating on a pilot basis, is intended to provide individual businesses with advice and guidance, help build organisational capability and enable a two-way dialogue with government. The UK Supply Chain Centre (Supply Chain Centre mission statement and action plan: https://www.gov.uk/government/publications/supply-chain-centre-mission-statement-and-action-plan) has a higher-level, policy-related brief focused around understanding and mitigating supply chain risk. It brings together a range of public and private sector databases to consider supply chain dependencies and chokepoints and will work with business on a sectoral basis in order to optimise policymaking.

Interestingly, a core message of ECJU’s Workshop on Military End-use Control was the centrality of economic security as a guiding principle behind that regime’s implementation in the current geopolitical landscape. Citing the proposition by the former Prime Minister, Sir Keir Starmer, in the UK government’s recent National Security Strategy (National Security Strategy 2025: Security for the British People in a Dangerous World: https://www.gov.uk/government/publications/national-security-strategy-2025-security-for-the-british-people-in-a-dangerous-world) that economic security is national security, MEUCs are presented not as restrictive control measures, but as a positive, enabling tool that allows society to seek innovation while protecting security. 

End-use and end-user are the key takeaways

If there was a single theme that recurred time and again throughout the day, it was the importance of understanding end-use, end-users and diversion risk. Whether expressed through government policy initiatives, new control regimes or updates to official guidance, the underlying message was clear: individual exporters need to become more proactive in accepting their share of the responsibility for mitigating risks that the goods, software and technology they send abroad could end up in the hands of bad actors. Importantly, those risks apply just as much in the economic security domain as they do in the more traditional military and WMD non-proliferation space. It’s more evidence, if any were needed, that in today’s environment, export control and sanctions compliance extends well beyond checking the export control lists.

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