Financial sanctions

This subtopic contains guidance on sanctions, how they apply 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 sanctions regime

‘Sanctions’ is the term used for a range of measures designed to have an adverse impact on foreign countries or designated persons (individuals or corporate bodies) for one or more specified purposes (often foreign policy, sometimes counter-terrorism). The measures apply prohibitions and requirements on the targets directly, but also on third parties who trade or otherwise deal with them. For detailed guidance, see Practice Note: International sanctions—an introduction—What are sanctions?

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 also known as a 'target'.

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

The types of measures that may be imposed include:

  1. financial sanctions

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