If you have any questions related to sanctions compliance, please raise them with [insert, eg your business group’s sanctions compliance representative]. This table contains contact information for you to use when you

Sanctions are intended to have a serious effect on the individuals, organisations and regimes they target. There is therefore a corresponding risk that sanctions targets may seek to circumvent the effect of sanctions. Understanding the risks of being involved in sanctions evasion and the warning signs and red flags to look out for should be a key part of your screening process. Failure to identify and manage red flags could expose you to criminal sanctions and/or regulatory and government fines. The methods used to evade sanctions are generally complex and sophisticated. You are unlikely to be dealing with a direct sanctions target, who could be identified through screening relevant sanctions lists, so you will need to be thorough with your due diligence investigations to determine whether a particular transaction would breach sanctions. If red flags are raised at any point in your due diligence, you need to get to the bottom of them. This Practice Note reflects guidance issued by the SRA and Law Society, together with key sanctions evasion guidance and

Property Disputes analysis: The Divisional Court has ruled that rent is not payable by contract-holders in Wales unless and until landlords provide them with a copy of Electrical Condition Reports (‘ECRs’) for their homes. This is the first reported decision on the interpretation of the Renting Homes (Wales) Act 2016 (RH(W)A 2016), which came into force on 1 December 2022. It introduced major changes to landlord and tenant law in Wales, entirely replacing the regime derived from the Housing Acts 1985 and 1988. Amongst many other matters, it introduced the concepts of an ‘occupation contract’ (ie tenancy agreement) and ‘contract-holder’ (ie tenant). It also introduced a raft of new provisions intended to ensure that all residential premises are fit for human habitation. Written by Tara O’Leary, barrister at Cornerstone Barristers, who acted for the successful defendants.

Sanctions must be considered throughout the life of a transaction and any resulting dispute. The 50 questions in this Checklist identify practical issues to consider from initial risk assessment and contract drafting through to the commencement and conduct of arbitral proceedings, recognition, enforcement and ultimate recovery. Sanctions issues are rarely neatly labelled as such. A designation or new sanctions measure arising midway through a contract can raise a series of practical questions: Can the contract still be performed? Can payments be made? Can counsel act? Can the institution and tribunal be paid? Can documents be transferred and witnesses heard? And, ultimately, can an award actually be enforced and the proceeds recovered? The existence of sanctions does not, however, necessarily prevent an arbitration from proceeding. Depending on the applicable sanctions regime and the circumstances, the issue may instead be whether particular acts, services or payments are permitted or require an exemption, licence or other authorisation. Sanctions may affect contractual performance, payment, participation in the arbitration, the

This Precedent Sanctions licence log is designed to help organisations keep a record of licences issued under the UK sanctions regime by, eg the Office for Financial Sanctions Implementation (OFSI)

Mealey’s: A New York federal judge on 22 April 2025 granted a motion for civil contempt sanctions against the majority shareholders of a Latin American telecommunications company for their ongoing failure to comply with five partial awards issued against them in an ongoing arbitration with the company’s minority shareholders.

The Republic of Belarus (Sanctions) (EU Exit) Regulations 2019, SI 2019/600, made under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018), create a UK sanctions regime in relation to Belarus. The Belarus sanctions regime is aimed at encouraging Belarus to: • respect democratic principles and institutions, the separation of powers and the rule of law in Belarus • refrain from actions, policies or activities which repress civil society in Belarus • investigate properly and institute criminal proceedings against the persons responsible for the disappearances of Yury Zakharanka, Viktar Hanchar, Anatol Krasouski and Dzmitry Zavadski • comply with international human rights law and to respect human rights • cease actions destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine, including by supporting or facilitating Russia's actions in respect of Ukraine • refrain from any other action which undermines or threatens peace, security or stability in Europe For information on the UK sanctions regime against Russia, see Practice Note: Sanctions regime—Russia. Key information The Republic of Belarus (Sanctions) (EU Exit) Regulations 2019, SI 2019/600

The Russia (Sanctions) (EU Exit) Regulations 2019, SI 2019/855, made under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018), create a UK sanctions regime in relation to Russia (the Russia sanctions regime). The Russia sanctions regime is aimed at encouraging Russia to: • cease actions which destabilise Ukraine, including actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine • promote the payment of compensation by Russia for damage, loss or injury suffered by Ukraine For information on the UK sanctions regime against Belarus, see Practice Note: Sanctions regime—Belarus. Key information The Russia (Sanctions) (EU Exit) Regulations 2019, SI 2019/855, ensure sanctions relating to Russia are implemented effectively in the UK. The Regulations entered into force on 31 December 2020 and replaced the previous EU sanctions regime relating to Russia’s actions in Ukraine. They impose various sanctions measures, as follows: Financial sanctions Immigration sanctions Trade sanctions Transport sanctions Director disqualification sanctions Yes Yes Yes Yes Yes For further information, see section: What’s prohibited? The territorial extent of the

Financial sanctions target behaviour, and have traditionally been aimed at: • terrorism • nuclear weapons development, and • human rights abuses (see Practice Note: Sanctions regime—global human rights and international humanitarian law) However, financial sanctions are increasingly creeping into the realms of more general criminal law, with sanctions imposed in relation to global anti-corruption and cyber-attacks—see, eg Practice Note: Sanctions regime—global anti-corruption. Cyber-attacks know no international boundaries and have increased in terms of intensity, complexity and severity. Malicious actors in cyberspace are active and able to execute successful operations on countries, affecting critical national infrastructure, democratic institutions, business and the media. These actors are demonstrating an increased risk appetite and may be motivated by economic, strategic, regional and/or financial gain. There has been a rise in the scale and impact of cyber-attack operations, with co-ordinated campaigns (as opposed to single incidents) that potentially allow wide-ranging access to thousands of victims in countries globally and causing significant financial and material damage. The purpose of the cyber sanctions regime is to deter those who are (or are considering) conducting

Financial sanctions target behaviour. The UK has a global anti-corruption sanctions regime, aimed at preventing and combatting serious corruption. This Practice Note explains the scope of the UK global anti-corruption sanctions regime under the Global Anti-Corruption Sanctions Regulations 2021, SI 2021/488. It explains the activities targeted by the regime, the sanctions imposed, who is covered and the relevant guidance published by the Office of Financial Sanctions Implementation (OFSI). It also considers practical aspects of the regime for businesses. For information on the statutory aims for the creation of sanctions regimes under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018), the obligations to publish guidance on those regimes and how designations may be made, varied and enforced, see Practice Note: The UK sanctions framework under SAMLA 2018. Key information The Global Anti-Corruption Sanctions Regulations 2021, SI 2021/488 enable financial sanctions and travel bans to be imposed on persons involved in serious corruption. They replace the Misappropriation (Sanctions) (EU Exit) Regulations 2020, SI 2020/1468 concerning misappropriation of state funds from any country outside the UK

STOP PRESS: This Practice Note has been updated to reflect the Global Human Rights and International Humanitarian Law Sanctions Regulations 2026, SI 2026/1071, which came into force on 15 October 2026. The relevant government guidance is being updated, and this Practice Note will be updated further to reflect that guidance once published. On 6 July 2020, the UK introduced its first autonomous sanctions regime under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018), through the Global Human Rights Sanctions Regulations 2020, SI 2020/680. These sanctions are commonly referred to as ‘Magnitsky sanctions’. The Global Human Rights and International Humanitarian Law Sanctions Regulations 2026 (human rights and international humanitarian law sanctions regime), SI 2026/1071 came into force on 15 October 2026, revoking and replacing the Global Human Rights Sanctions Regulations 2020, SI 2020/680 and expanding the activities targeted by the regime. The Global Human Rights and International Humanitarian Law Sanctions Regulations 2026, SI 2026/1071 expand the criteria for designating persons but do not themselves designate additional individuals

UK financial sanctions obligations apply to all businesses and persons in 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 (herein referred to as firms). 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 regulatory requirements and expectations for a firm's financial sanctions systems and controls in relation to sanctions screening on the basis of the following guidance: the FCA’s Financial Crime Guide (FCG); the FCA’s Financial Crime Thematic Reviews (FCTR); FCA supporting guidance such as its multi-firm reviews setting out good and poor practice on sanctions systems and controls and the Joint Money Laundering Steering Group (JMLSG) Guidance, Part III, Chapter 4 on compliance with the UK financial