The Office of Financial Sanctions Implementation (OFSI) has published a report Legal Services Threat Assessment (April 2025), addressing threats to UK financial sanctions compliance. The report aims to assist UK stakeholders in better understanding and protecting against threats to compliance ‘…to assist stakeholders with prioritisation as part of a risk-based approach to compliance’.
The key finding of the report is – ‘Since February 2022, the legal services sector has submitted the second highest number of suspected breach reports to OFSI by sector, accounting for 16% (compared with 65% submitted by the financial services sector). Solicitors’ firms and barristers’ chambers submitted 98% of these suspected breach reports, while TCSPs and other legal services providers submitted the remaining 2%’.
The report reiterates the crucial role legal services providers play in ensuring compliance with UK financial sanctions both within and outside their sector. They provide services to a range of UK and international clients (including, in some cases, designated persons or DPs), to help them comply with UK financial sanctions. In providing services to DPs, legal services providers are uniquely positioned to identify suspected breaches. TCSPs provide their services to a variety of clients and in addition to asset freeze prohibitions, must ensure compliance with Russia-related trust services sanctions.
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