Context
The FCA has a web page which sets out key information in relation to sanction measures in relation to Russia. The articles below also contain relevant information. If you require a licence to permit any activity which would otherwise be prohibited by sanctions regulations, you must contact the relevant Government department. The FCA expects firms to have established systems and controls to counter the risk that they might be used to further financial crime and this includes compliance with financial sanctions obligations.
Key points to note
- Firms should screen against the UK Sanctions List to meet these new sanctions measures and screen against the OFSI list of asset freeze targets for financial sanctions obligations. You are legally obliged to report to OFSI if you know or suspect that a breach of financial sanctions has occurred; if a person you are dealing with, directly or indirectly is a designated person; if you hold any frozen assets; if knowledge or suspicion of these come to you while conducting your business. You must contact OFSI at the earliest opportunity, and you should also notify the FCA.
- The FCA’s expectations of firms’ systems and controls in relation to compliance with financial sanctions are set out in FCG 7 of the FCA’s Financial Crime Guide including examples of good and poor practice in relation to firms’ governance, risks assessment and approaches to screening in relation to financial sanctions. Where transactions give rise to concerns about sanctions evasion or money laundering firms should also consider their obligations to report to the UK Financial Intelligence Unit (UKFIU) at the National Crime Agency (NCA) under the Proceeds of Crime Act 2002.
- For further details on financial sanctions you should contact OFSI or, for trade and export sanctions, you should contact the Department for International Trade’s Economic Control Joint Unit. Applications must be made in advance of any business agreement or transaction taking place.
Next actions
None – for information and awareness – but see the items noted below.