The SRA has updated its financial sanctions guidance to solicitors to make sure they adhere to the Government’s sanctions on Russian nationals and organisations in light of the conflict in Ukraine.
A reminder was published by the SRA in February that firms needed to check the latest Government lists to make sure firms did not act for clients subject to sanctions and reminding firms that they needed to have in place appropriate policies to ensure compliance with the sanctions legislation, including undertaking regular and appropriate checks of sanctions lists and of the need to make a report to the Office of Financial Sanctions Implementation (OFSI) if they suspect a customer of their firm is a designated person under the financial sanctions regime
This reminder has now been updated to provide further detail, and remind law firms that this is a fast-moving situation and the sanctions list is being updated on a very regular basis. For example, a client might not have been on the list when a firm started a piece of work for them, but could be added before the work is complete.
As this is a fast moving situation OFSI allows firms to sign to receive alerts on the latest sanctions changes and the SRA have also issued guidance on balancing duties in litigation, particularly in relation to concerns about strategic litigation against public participation (SLAPP). The guidance entitled “Conduct in Disputes” can be found at www.sra.org.uk/solicitors/guidance/conduct-disputes/
The information also refers to other areas of compliance, such as requirements on anti-money laundering and ceasing to act for clients.
See also the SRA’s updated news release “The importance of complying with Russian financial sanctions” and the The Financial Conduct Authority’s “helpful guidance on the sanctions regime”.