Financial sanctions

Financial sanctions

This subtopic contains guidance on the financial sanctions regime, and how it applies to law firms, and the systems and controls required to help firms comply. It contains flowcharts covering key processes and helpful checklists. Finally, it contains Precedents covering senior management responsibility, risk assessment, policies, screening, breaches, training and monitoring.

Understanding the financial sanctions regime

Sanctions are international measures aimed at:

•
encouraging a change in the behaviour of a particular country or regime
•
applying pressure on particular countries or regimes to comply with certain objectives
•
preventing and suppressing terrorist financing

They are also used as a last-resort enforcement tool when international peace and security has been threatened.

A designated person, entity or regime subject to sanctions that are effective in the UK is known as a 'target'.

Sanctions may be imposed by the United Nations (UN) Security Council or HM Treasury.

See Practice Note: Understanding the financial sanctions regime.

The financial sanctions regime v the anti-money laundering regime

Anti-money laundering (AML), counter-terrorist financing (CTF) and counter-proliferation financing requirements are familiar ground for most law firms (if not, see our AML,

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