This Practice Note explains the Financial Conduct Authority’s (FCA) expectations for trade sanctions and counter-proliferation financing (CPF) systems and controls. It incorporates FCA guidance in the Financial Crime Guide (FCG) 7, multi-firm reviews and the Financial Crime Thematic Review (FCTR) 15. It is particularly relevant to financial services firms which conduct trade finance or project finance, and to insurers, but applies to all firms: • regulated by the FCA under the Financial Services and Markets Act 2000 (FSMA 2000) • supervised by the FCA under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, SI 2017/692 (MLRs) together, firms. Trade sanctions and CPF are considered together in this Practice Note because the FCA expects firms’ systems and controls to address both trade sanctions risks and, where relevant, the risk that their services may support weapons proliferation through prohibited trade. This reflects the FCA’s view that some sanctions regimes are aimed at deterring the proliferation and use of chemical weapons,