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Sanctions

Sanctions are used for a number of purposes, including pressurising a particular country or regime to change their behaviour, or to prevent terrorist financing.

The Treasury has established within it the Office of Financial Sanctions Implementation (OFSI). Its principle aims are to:

  • increase awareness of and compliance with financial sanctions;
  • ensure that sanctions breaches are rapidly detected and effectively addressed; and
  • provide a professional service to the public and industry on financial sanctions issues.

The financial sanctions regimes in force in the UK include country-based regimes, as well as those directed at terrorist organisations. The HM Treasury website provides details of all the current financial sanctions regimes in force and of the statutory instruments giving effect to these sanctions. 

You can also subscribe to receive updates when sanctions are updated. 

Further guidance on Sanctions, Embargos and Restrictions can be found on the HM Treasury website, along with a form for reporting suspected breaches

We would recommend considering a sanctions check as an important part of your customer or client due diligence.

NCA have published guidance on the financial profiles of foreign terrorist fighters.

Reporting obligations

All accountants in practice, as well as others working within the regulated sector in the UK, will be aware of their obligations under the Money Laundering Regulations 2007 including the legal obligation to report their suspicions to the National Crime Agency (NCA).

All businesses, organisations and individuals now have an obligation to report information about sanctions breaches.

You must report to OFSI as soon as practicable if you know or have reasonable cause to suspect that a person:

  • is subject to financial sanctions
  • has committed an offence under the regulations

OFSI have updated their Guide to Financial Sanctions to help individuals and businesses understand what they should report and when.

There is a standard template that must be used which can be found here.

Members should be aware that making a SAR to the NCA does not remove the requirement to make a report to OFSI.