How to Comply with UK Sanctions Regime: Guidance for SRA-Regulated Firms
The UK Government’s financial sanctions regime is an ever-changing landscape that can be complex and challenging to navigate. This regime applies to all firms that provide legal services, not just those that are captured by the anti-money laundering regulations. Failure to comply with the sanctions regime can result in severe consequences, including criminal charges, fines, and imprisonment. It is, therefore, essential for law firms to understand their obligations and how to stay compliant with the regime. In this blog post, we will provide practical guidance and tips for law firms on how to comply with the UK Government’s financial sanctions regime. From identifying designated persons to fulfilling reporting obligations, we will cover everything you need to know to avoid any breaches and ensure compliance with the sanctions regime.
As an SRA-regulated firm, it is essential to understand the UK Sanctions Regime and comply with it to avoid any breaches. The sanctions are imposed by the government to achieve specific foreign policy or national security objectives. A breach of the UK sanctions is a criminal offence and can result in a fine and/or imprisonment.
The sanctions regime spans many pieces of legislation, and it is challenging to keep up with the pace of change. Firms must understand their obligations and comply with the regime to avoid any enforcement actions.
This blog post will provide you with some practical advice on how to comply with the UK Sanctions Regime.
- Identify designated persons
Designated persons are individuals, entities, planes or ships subject to sanctions. Firms must carry out thorough due diligence checks to identify whether a person (whether natural or legal) is designated. It is also essential to consider any counter-parties, beneficial owners or individuals with possible control of the entity.
- Avoid providing services to designated persons
Generally, you must not undertake paid work for a designated person unless you have been granted a license to do so by the Office of Financial Sanctions Implementation (OFSI), or are doing so under the terms of a general license. Unpaid work may be allowable where it does not circumvent the sanctions regime or provide financial advantage to the designated person.
- Fulfill reporting obligations
Firms must fulfill their reporting obligations under the UK Sanctions Regime. This includes reporting any suspicions of breach or attempted breach of sanctions. Firms must also report any suspicions of money laundering related to sanctions breaches.
- Keep up to date with changes
The number of designated persons and the prohibitions they are subject to has expanded at a rapid pace. Firms must keep up to date with any changes to the sanctions regime to ensure compliance.
- Seek expertise
Working within the sanctions regime is complex and challenging, and firms should not seek to provide these services without first gaining the necessary expertise to do so correctly. Firms may also consider seeking external advice or training to ensure compliance with the regime.
Free SRA webinar provides a in-depth introduction to the fast-changing sanctions regime
Looking to stay compliant with the UK Government’s financial sanctions regime? Join the SRA for a free webinar on Wednesday 3 May 2023 from 12.00 to 13.00, featuring expert speakers Ross Gillson, Head of AML Policy, and Mandeep Sandhu, Head of AML Proactive Supervision.
The sanctions regime applies to all firms that provide legal services, not just those that are captured by the anti-money laundering regulations. This webinar will provide a practical introduction to the fast-changing sanctions regime, including how to comply and what to do if you find yourself in breach.
During the webinar, you will gain insights into the following topics:
–An overview of the sanctions regime
-How sanctions might affect your practice
-What to look out for
-Where to find guidance
-How to check for sanctioned status
-Enforcement, reporting and mitigation.
Book your free place now and send in your questions in advance or during the webinar. A link will be sent to view the webinar a couple of days before broadcast.
Don’t miss this opportunity to stay compliant with the UK Government’s financial sanctions regime.
If you require further information on how technology solutions like Verify 365 can help you comply with the new sanctions regime. Book a free demo.