Sanctions breach—panic sheet

The following Risk & Compliance precedent provides comprehensive and up to date legal information covering:

  • Sanctions breach—panic sheet

Sanctions breach—panic sheet

    1. 1

      Consider seeking external advice

      Given the complicated nature of most sanctions regimes, the potential for offences to have been committed across multiple jurisdictions, and the complex position in relation to privilege and in-house lawyers, it is often prudent to seek specialist advice from external lawyers as soon as a breach is detected.

    1. 2

      Cease dealing with the sanctioned entity/person/funds/etc

      You should cease dealing with the sanctioned entity/person/funds etc immediately.

      Suspend the transaction but do not return funds to the sanctioned entity or person.

      If funds have arrived in the UK from a designated person outside the EU, government policy requires these funds to be frozen on arrival in the UK.

    1. 3

      Begin a response audit trail

      In the immediate aftermath of the breach, you should document, through an audit trail, the steps you have taken in responding to a sanctions breach.

      Set up your response audit trail using our [Sanctions post-breach record of actions].

      Retain all relevant documents (eg, emails, invoices) and ensure they are stored securely.

    1. 4

      Determine which

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