The Financial Conduct Authority (FCA) has provided some examples of good practice for sanctions systems and controls in Part 7 in its guide, FCG Financial Crime Guide: A firm’s guide to countering financial crime risks (FCG) and in its Financial Crime Thematic Reviews (FCTR) Part 8 Financial services firms’ approach to UK financial sanctions. The information contained in this Practice Note is taken from these sources. It also contains information taken from guidance issued by the SRA for law firms on complying with the UK Sanctions Regime, and its anti-money laundering annual reports. Our Financial sanctions compliance—checklist identifies specific Precedents you could use or adapt to help you demonstrate good practice in financial sanctions compliance. Governance and senior management responsibility Good practice Poor practice An individual of sufficient authority is responsible for overseeing the firm’s adherence to the sanctions regime.Making it clear at what stage customers are screened in different situations, eg when customers are passed from agents or other companies in the group.There is appropriate escalation of actual target matches, potential

Corporate Crime analysis: The Office of Financial Sanctions Implementation (OFSI) has updated its guidance on financial sanctions enforcement and monetary penalties following a public consultation. The purpose of the updates is to create a quicker, easier and more transparent civil enforcement process. The most important changes include the creation of new penalty discounts and the introduction of fixed monetary penalties for specific low-level breaches. The maximum statutory penalty is also expected to rise. Written by Rachel Barnes KC and Miranda Zeffman, barristers at Three Raymond Buildings.

The financial sanctions guidance for insolvency practitioners which covers what financial sanctions are, reporting obligations and prohibited persons has been updated to reflect the closure of the Office of Financial Sanctions Implementation (OFSI) Consolidated List on 28 January 2026. The UK Sanctions List is the sole authoritative source for all UK sanctions designations.

This document contains [insert organisation’s name]’s internal watch list, which supplements data

Instructions on completing this form You must complete this form in full, attach any required documentation (as set out below), and pass it to [your sanctions representative] without delay where you discover a possible target match through our financial sanctions screening process. You must submit this form before taking any other steps. 1 Details of the

This Precedent Financial sanctions match report record is intended to be used to log sanctions match

1 Introduction 1.1 We have performed an organisation-wide risk assessment of the areas where we are most at risk of breaching financial sanctions or being exposed to customers subject to financial sanctions. This document records the risks we have assessed and conclusions we have reached, including how we will mitigate the risks. The person responsible for this assessment is [insert name/role]. 1.2 Our assessment included consideration of: 1.2.1 our customers and their counterparties; 1.2.2 the geographical areas we operate in[, including sanctions regimes in other countries in which we operate]; 1.2.3 the [services AND/OR products] we offer; 1.2.4 our internal or operational risks. 2 Overview of the organisation Size and nature of the organisation [Insert details] Staff [Insert details eg headcount, composition of staff base, staff turnover, supervisory structure and any other relevant employee metrics] Description of practice areas and their relative size/significance to the business [Insert details] Customer types [Insert details ie, are your customers individuals, UK corporate entities, overseas entities (EU or global), entities listed on a regulated market, credit or financial institutions, government or local authorities etc?] Sources of customers [Insert details—consider whether you have a restricted or closed customer base, or any referral arrangements, or reciprocal arrangements

1 Introduction This financial sanctions policy sets out the procedures we have developed to comply with financial sanctions requirements made under the UK sanctions regime that apply to our business[ across every jurisdiction in which we operate]. 2 What are financial sanctions? 2.1 Financial sanctions are non-permanent international restrictions aimed at: 2.1.1 encouraging a change in the behaviour of a particular country or regime; 2.1.2 applying pressure on particular countries or regimes to comply with certain objectives; 2.1.3 preventing and suppressing terrorist financing. 2.2 Financial sanctions are also used as a last resort enforcement tool when international peace and security has been threatened. 2.3 Financial sanctions restrict dealings in money and the provision of financial services—they can include the prohibition of funds transfers to and from certain countries, individuals or entities. 2.4 They are designed to have an adverse impact on persons (individuals or corporate entities) that are designated or (for some sanctions) connected with a prescribed country, in a number of different ways. These can include freezing their funds or economic resources, and/or preventing: 2.4.1 funds or economic resources being made available to them (or for their benefit) or received from them (directly or indirectly);

UK financial sanctions obligations apply to all individuals and legal entities who are within or undertake activities within the UK; this Practice Note focuses on the implications for firms regulated by the Financial Conduct Authority (FCA) under the Financial Services and Markets Act 2000 (FSMA 2000) and for e-money and payment institutions and cryptoasset businesses within the FCA’s supervisory scope. The FCA is not responsible for enforcing financial sanctions, its role is to ensure that the firms it supervises have adequate systems and controls to comply with the UK’s financial sanctions regime. This Practice Note addresses the FCA's requirements and expectations for a firm's financial sanctions systems and controls in relation to: • risk assessments • policies and procedures • governance and senior management responsibility • management information (MI) • resource provision • communication, training and staff awareness • international sanctions compliance The FCA also expects firms’ sanctions systems and controls to address: • reporting obligations to the FCA, Office of Financial Sanctions Implementation (OFSI) Office of Trade Sanctions

This Financial sanctions target match investigation flowchart illustrates the step-by-step process to be taken when a potential financial sanctions target (designated person) match has been identified. It is intended to be used to ensure all relevant points are considered. Note 1 See Precedent: Financial sanctions match report form. This match report form is intended for use by staff to report possible financial sanctions target (designated person) matches discovered through the screening process. This form should be completed in

Sanctions are non-permanent restrictions or prohibitions imposed by governments that regulate how its people and companies engage with sanctions target countries or regimes. Sanctions are a foreign policy tool and can be made against countries, regimes, organisations, individuals and entities. Sanctions will normally be either directed at doing trade with the sanctions

Please click for an Excel version of this register. General Insert course name/description and reason for training.