Sanctions Policy

This update clarifies when sanctions authorisation is required for legal services, payments and the underlying transaction. It distinguishes financial sanctions licensing from trade sanctions licensing and explains why an OFSI licence does not authorise otherwise prohibited trade activity.

This latest wording replaces the expired OFSI General Licence reference and clarifies the 14-day reporting deadline, MLRO approval and six-year recordkeeping requirements.

Updated paragraph partially based on SRA 2025 guidance. This version provides updates based on legislative changes and recent proactive supervision.

New draft section outlining the introduction of OFSI General Licence INT/2025/7323088, allowing legal firms to receive payments from designated persons without an individual licence, subject to specific conditions.

Updated to reflect the consolidation of all UK sanctions into the single “UK Sanctions List”, replacing older HM Treasury and trade/financial lists.

Expansion of the policy to require formal documentation whenever the firm relies on the General Licence, including client details, payment records, and confirmation of compliance.

Revised to include mandatory staff training on the new General Licence and single sanctions list, ensuring awareness before undertaking designated-person matters.

Broadened to include obligations to self-report any breaches or misuse of the General Licence, or failure to use the updated UK Sanctions List.

Draft wording making it clear that trust services must not be provided where there’s a connection to Russia, including beneficiaries or those likely to benefit financially. The definition of “connected” is based on residence or incorporation, not nationality alone, and the restriction applies to creating, managing, or arranging trusteeship.

Draft wording should confirm that giftors must undergo the same due diligence as clients to avoid indirect links to Designated Persons (DPs), and that no funds, including payments on account, may be accepted before due diligence is complete, in line with sanctions requirements.

Provisional wording noting OFSI’s April 2025 warning on the misuse of trusts and complex structures by Russian DPs, often involving family members or associates. Also reflects underreporting concerns by TCSPs and recent UK/EU sanctions on Russia’s shadow fleet and financial institutions, reinforcing the need for strict scrutiny and reporting.

Updated wording in light of the updated guidance by the SRA on 1st May 2025. Note that red flags should now include self-reporting responsibilities and the need to screen staff during onboarding.

Updated wording in light of the updated guidance by the SRA on 1st May 2025. Note that red flags should now include self-reporting responsibilities and the need to screen staff during onboarding.