Important update March 2022
Following the UK Government imposing sanctions on Russia, you all have a vital role to play in ensuring all measures and restrictions are complied with.
Breaching the financial sanctions requirements can result in criminal prosecution or a fine by OFSI. Our Code of Conduct requires all firms and individuals that we regulate to keep up to comply with the law and regulations relating to their work. Therefore, we would take disciplinary action should we see evidence of serious non-compliance.
Your firm must have appropriate policies in place to ensure you comply with sanctions legislation, including carrying out regular and appropriate checks of sanctions lists, and we expect to see this evidenced. If your firm is authorised by another regulator, you should check their guidance.
You must also understand when you need to apply for a licence to deal with a sanctioned individual or entity.
Firms must also make a report to the Office of Financial Sanctions Implementation (OFSI) if they suspect a customer is a designated person under the financial sanctions regime. You have responsibilities under this regime to safeguard the UK and protect the reputation of the legal services industry.
