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UK Sanction measures in relation to Russia

Members in Practice (MiPs) in the UK will no doubt be aware from the news media that the Prime Minister announced a tranche of sanctions imposed by the UK on Russia on 22 February 2022.

As MiPs providing accountancy services in the UK you are legally required to adhere to these sanctions.  The Office of Financial Sanctions Implementation (OFSI) highlight that they have the power to levy civil monetary penalties for breaches of financial sanctions. 

CIMA’s Anti-Money Laundering regulator, the Office for Professional Body Anti-Money Laundering Supervision (OPBAS), has asked us to remind you of its expectations in respect of sanctions.  A statement published by the Financial Conduct Authority is drawn to your attention.  The FCA statement reminds MiPs of your responsibilities in respect of sanctions. 

Whilst you may consider the risk to be small of being engaged by individuals (or their associates) who are subject to sanction, it is especially important to be aware of this risk and to take steps to comply with the legal requirements should that be the case.
For further details on financial sanctions you should contact OFSI (link below) or, for trade and export sanctions, you should contact the Department for International Trade’s Economic Control Joint Unit.

You may also contact CIMA for guidance If you have concerns about acting for a client who may be subject to sanctions. Please contact aml@aicpa-cima.com in such circumstances.

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