The SRA is now actively asking law firms to explain what steps they take to comply with the UK Sanctions regime. (Indeed it is wise for you to ensure that you also do not breach the sanctions regimes of the EU or the USA, otherwise you may find banking facilities for your organisation are withdrawn.) We are certain that they will follow the same approach as they have for AML compliance - and follow up their initial questions with later audits to check.
With regard to AML compliance, the SRA want firms they regulate to have Independent AML Audits to be carried out. These are to check the actual operation of the firm's AML policies & procedures. This makes sense. Its little use just having perfect policies that just gather dust on the shelf. We expect that they will want firms to carry out Independent Sanctions Compliance Audits. Indeed, even if they done, we would recommend this. Remember that compliance with the Sanctions regime has Strict Liability. Compliance is overseen by OFSI - part of HM Treasury.
We Can Help
We already carry out Independent AML Audits. The Sanctions Compliance Audits will follow a similar pattern.
1. An Interview with the COLP & COFA (who may be the same person)
2. A Review of Sanctions Policies, Procedures and Controls
3. Review a number of sample files
4. Interview some staff members
5. Report in writing on our findings with Recommendations
6. Follow Up Remote Review to ensure the recommendations have been implemented
All work is carried out remotely unless by separate arrangement.
If you go for a similar Independent AML Review at the same time we offer a discounted combined price of £1,500 + VAT (which would mean a discount of £245 + VAT on the combined price)
(This is on the assumption of 1 office & up to 50 staff. If there are more offices you wish to have included, the charge will be £250 + VAT per additional office. There will be an additional charge of £250 + VAT for each 25 staff over 50 in number, but this will not duplicate to the office charge.)
Other Sanctions compliance help
Feel free to contact us, ideally by using the 'How can we help you?' form below.