The SRA has written to more than 1000 firms offering advice and guidance on complying with the UK’s financial sanctions regime.
The SRA gathered data from a number of firms and based on the responses provided, have identified a large number of firms that had indicated they had poor controls in place.
The SRA then sent out letters which included guidance on complying and guidance on completing firm-wide sanctions risk assessments, including a template for firms to use.
The SRA also used this opportunity to include information on client identification and screening, which firms can do for free using the online tool offered by the Office of Financial Sanctions Implementation (OFSI).
The UK financial sanctions regime is operated by OFSI and the measures are imposed by the Government to achieve specific foreign policy or national security objectives. A breach of UK sanctions is a criminal offence and is punishable by a fine and/or imprisonment.
Juliet Oliver, SRA Deputy Chief Executive, said:
“Strengthening the financial sanctions regime is an important part of the government’s response to war in Europe, and law firms have to a key role to play. The sanctions regime applies to all firms that provide legal services, not just those that are captured by the anti-money laundering regulations.
‘Firms we have written to responded to our survey last year by saying they did not have or were not aware of a written-down firm-wide risk assessment, or the process for identifying an ultimate beneficial owner. The support we’ve provided should help address these issues and help firms remain compliant.”
OFSI has also published guidance on the sanctions legislation.
The SRA have stated that they have an on-going programme of on-site sanctions inspections to test compliance with the regime, and they will also be undertaking a programme of proactive desk-based reviews to test a sample of these firms’ controls later this year.