The Solicitors Regulation Authority (SRA) has published important guidance on sanctions compliance in its latest update. This reinforces the need for firms to maintain robust systems and controls under the UK sanctions regime.
Find the full guidance here.
Key Messages from the SRA
“Sanctions remain a key regulatory focus.”
The SRA highlights that compliance with sanctions obligations is critical and will continue to be a priority in its supervisory activities.
“All firms should ensure that their sanctions controls are proportionate and kept under regular review.”
This means firms must not only have systems in place but also actively monitor and update them.
“Assess and document your sanctions risk in writing.”
The SRA expects firms to carry out formal risk assessments and maintain clear records.
“Carry out appropriate sanctions screening of new and existing clients.”
Screening should be embedded in onboarding and ongoing monitoring processes.
“Ensure staff understand when and how to report to the Office of Financial Sanctions Implementation (OFSI).”
Training and awareness are essential to avoid breaches and regulatory action.
Why This Matters
The UK Government has introduced a single, definitive UK Sanctions List, and OFSI has issued a new General Licence (INT/2025/7323088) for legal services. These changes mean firms must review their internal systems and client-screening arrangements to ensure compliance.
What Should Firms Do Now?
- Update sanctions policies and procedures to reflect the latest SRA guidance.
- Implement or enhance screening tools for clients and transactions.
- Train staff on sanctions risks and reporting obligations.
- Establish clear escalation and reporting processes for suspected breaches.
- Monitor updates from OFSI and the SRA to stay compliant.