A breach of UK sanctions is a criminal
offence, punishable by a fine or imprisonment.
The Solicitors Regulation Authority (SRA)
announced this week it has written to all the firms concerned, offering
guidance on compliance, along with a template for firms to use.
Juliet Oliver, SRA deputy chief executive,
said: ‘Strengthening the financial sanctions regime is an important part of the
government’s response to war in Europe, and law firms have a key role to play.
‘The sanctions regime applies to all firms
that provide legal services, not just those that are captured by the anti-money
laundering regulations. Firms we have written to responded to our survey last
year by saying they did not have or were not aware of a written-down firm-wide
risk assessment, or the process for identifying an ultimate beneficial owner.’
Last week, the UK, US and Australia imposed co-ordinated
sanctions against key figures involved in financing Hamas and Palestinian
Islamic Jihad (PIJ). This is the third round of sanctions by the UK against
Hamas and PIJ since the 7 October attacks. Previous rounds sanctioned other
top-ranking officials and financiers of Hamas.
The Foreign Office said the asset freezes and
travel bans target five individuals, including financier Zuheir Shamlakh, who
is believed to have used his money exchange and cryptocurrencies to move large
amounts of Iranian funding to Hamas ahead of the 7 October attacks, using
legitimate businesses as a front.
According to a report published last week by
market intelligence specialists Diligent, ‘Compliance trends 2024’, 21,784 new
sanctions were imposed in 2023 (a 50% increase), making third party due
diligence a top priority for compliance professionals.
Josh Black, editor-in-chief at Diligent,
said: ‘With sanctions changing rapidly, it is increasingly important for
companies to have robust and transparent compliance processes in place.’
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