Knowledge Base

The UK imposes sanctions on a range of individuals, entities and jurisdictions. These include trade, sanctions, immigration and aircraft & shipping sanctions to support foreign policy and national security objectives.

Other countries have their own sanctions regimes – if your client operates overseas you should make yourself aware of the relevant sanctions regimes of that jurisdiction.

You should consider the supply chain and declared and potential ultimate end user of your client services or products, including the potential for them to be dual use items.

The MLR2022 amendments made a requirement of practices to assess and mitigate the risk of proliferation financing. All practices must include an assessment of this from September 2022.

Proliferation financing relates to the act of providing funds or financial services for use, in whole or in part, in the manufacture, acquisition, development, export, trans-shipment, brokering, transport, transfer, stockpiling of, or otherwise in connection with the possession or use of, chemical, biological, radiological or nuclear weapons (CBRN), including the provision of funds or financial services in connection with the means of delivery of such weapons and other CBRN-related goods and technology, in contravention of a relevant financial sanctions obligation.

You are not required to remove risk from your client or avoid taking on clients with risk present, however, you must put relevant and proportionate measures in place to address any risks that have been identified.

All clients must be subject to ongoing monitoring and review that reflects the individual client risk assessment outcome. Low risk does not mean no risk.