The government has imposed a tranche of sanctions on Russia in response to the situation in Ukraine. The Law Society’s guidance on the UK sanctions is important and proportionate, and all of us must do what we can to learn what steps we can take and safeguard the reputation of the profession and the rule of law, writes David Little, a Partner in our Corporate and Commercial department.
The new sanctions are aimed at encouraging Russia to cease actions destabilising, undermining or threatening the territorial integrity, sovereignty or independence of Ukraine.
All firms regulated by the Solicitors Regulation Authority (SRA) must have appropriate policies in place to make sure they comply with sanctions legislation.
This includes carrying out regular and appropriate checks of sanctions lists.
The guidance sets out:
- the criminal offences under the regime
- how to carry out a risk assessment
- obligations to check clients against sanctions lists
- how to apply for a licence to act for a client on a sanctions list
- your reporting obligations
SRA guidance on the importance of complying with sanctions
The SRA has published new guidance covering:
- financial sanctions
- anti-money laundering
- strategic litigation against public participation (SLAPPs)
- continuing to act for clients
The guidance highlights that the SRA are “commencing a process of spot checks on firms to assess compliance with the financial sanctions regime”.
It’s important that all firms ensure that they immediately review their policies, controls, procedures and sanctions compliance.
Stephanie Boyce, President of the Law Society, said: “We stand in solidarity with the Ukrainian people, the Ukrainian National Bar Association and the Ukrainian Bar Association.
“We also stand with the Russian people who oppose their government’s illegal invasion of Ukraine, and lawyers who are defending the rule of law in the region.
“We condemn the actions of the Russian Federation, which are in contravention of international law. There is no doubt that these actions are a direct threat to the rule of law.”
David Little is a Partner at Bishop & Sewell in our expert Corporate & Commercial team. If you would like to contact him please quote Ref CB288 on either 020 7631 4141 or email email@example.com.
The above is accurate as at 16 March 2022. The information above may be subject to change during these ever-changing times.
The content of this note should not be considered legal advice and each matter should be considered on a case-by-case basis.