SRA Sanctions Guidance – this was updated on 5th August 2024

This guidance was first published on 28 November 2022. This version provides updates based on legislative changes and our more recent proactive supervision. The major changes from our previous version are as follows:

  • References to the newness of the sanctions regime have been updated throughout to reflect its more established status.
  • The document has been restructured to move key information relevant to all firms to the top, followed by specific guidance for firms operating under the sanctions regime.
  • Additional feedback showcasing good practices from recent sanctions inspections has been incorporated throughout.
  • Controls for all firms: A new case study has been added to illustrate how firms may inadvertently become involved in the sanctions regime.
  • Red flags for attempted circumvention of the sanctions regime: Updated red flags now include self-reporting responsibilities and the need to screen staff during onboarding.
  • Reporting requirements: These have been clarified, and a new section has been added on when you must report to us.
  • Licensing: Further clarification on staying compliant with licence responsibilities has been provided.
  • Other resources: We have updated links to external information."

c) An AML & Sanctions Manual

d) AML Training

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