Why Did Export Control Investigations at HMRC Appear to Plummet in 2025? Corker Binning Manager Partner, Andrew Smith Quoted in Global Investigations Review

HMRC’s latest enforcement figures have prompted discussion after suggesting a sharp decline in criminal investigations into suspected breaches of export controls in 2025.  However, the figures reflect a change in the way HMRC reports its data, with trade sanctions investigations now reported separately from export control cases. Even when the two are combined, enforcement activity still appears lower than in 2024, but one notable trend is the increasing value of compound settlements.

Speaking to GIR, Corker Binning Partner, Andrew Smith said: “We’ve seen an increase in the fines that are being offered and imposed and, when prosecution budgets are constrained, I can only see offers for compound settlements increasing over time.”

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