Sanctions compliance

Copyright © 2025 LexisNexis

This Overview is a guide to the Lexis+® UK Financial Services subtopic Sanctions compliance and includes links to appropriate materials. UK sanctions obligations apply to all businesses and persons in the UK; this sub-topic focuses on the implications for firms regulated by the Financial Conduct Authority (FCA) under the Financial Services and Markets Act 2000 (FSMA 2000), cryptoasset firms registered with the FCA under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, SI 2017/692 (MLRs), and payments and e-money firms supervised by the FCA (herein referred to as firms), in their compliance with sanctions.

What are international sanctions?

Sanctions regimes are a tool of foreign policy affecting businesses or persons and are typically used where international peace and security is threatened. They can:

  1. •

    encourage a change in the behaviour, policy or activity of the target person, entity, government or country

  2. •

    apply pressure on a target to comply with certain objectives, and

  3. •

    enforce measures where diplomatic efforts have failed

Sanctions regimes are reviewed, lifted, revoked or adapted in the light of changes in the behaviour

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Latest Financial Services News

FCA, PRA and HMT respond to HoL FSRC report on financial services competitiveness and growth

The Financial Conduct Authority (FCA), Prudential Regulation Authority (PRA), and HM Treasury (HMT) have published letters in response to the House of Lords Financial Services Regulation Committee’s (FSRC) June 2025 report ‘Growing Pains: clarity and culture change required’, which examined how financial regulators are embedding their secondary objective to promote international competitiveness and growth . The responses outline reforms to authorisation processes, supervisory models, rule simplification and redress systems. The FCA also addressed questions on its proposed motor finance redress scheme.

FCA response to HoL FRSC confirms scope and modelling approach for proposed motor finance redress scheme

The Financial Conduct Authority (FCA) has published a letter by its chief executive, Nikhil Rathi, in response to the House of Lords Financial Services Regulation Committee’s (FSRC) questions on the proposed motor finance redress scheme. The FCA stated that complaints dating back to 2007 may be eligible, referencing Canada Square Operations Ltd v Potter [2023] UKSC 41, which held that deliberate concealment of commission arrangements can suspend the statutory limitation period under the Consumer Credit Act 1974. It indicated that a structured redress scheme may offer a more consistent and efficient approach than resolving complaints through litigation or the Financial Ombudsman Service (FOS), and noted that while the Court of Appeal’s October 2024 ruling caused short-term disruption, the motor finance market has since stabilised. A cost-benefit analysis and further modelling is set to be published alongside the consultation in October 2025.

Financial Services weekly highlights—4 September 2025

This week's edition of Financial Services weekly highlights includes: HMTs policy paper with BoE and PRA on financial crisis management MoU; an expert News Analysis on Fraud law putting fund managers under compliance spotlight; Council of the EU’s proposal on amendments to several investment regulations to boost guarantee efficiency and simplify reporting; FATF’s toolkit and guidance to support national money laundering risk assessments; plus dates for your diary over the coming week.

Financial Services—other developments (4/9/2025)

A round-up of other developments, which have not been covered in full by the LexisNexis Financial Services practical guidance team but may nevertheless be of interest.

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