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Russian sanctions reminder

Details were provided in the March newsletter and May newsletter on the need for members to fully understand assets under the ownership and control of clients and the impact on any insolvency appointments. New sanctions against Russian and Belarussian individuals and corporations continues to rise, and the position is fast-moving. It is therefore essential that that your Customer Due Diligence (CDD) policy includes checking for updated sanctions and that checks are carried out not only on new appointments, but where payments are due to be made to charge-holders, creditors and shareholders.

Members should also remember to report to the Office of Financial Sanctions Implementation (OFSI) any knowledge or suspicion of a breach of financial sanctions and should remember that reports to OFSI are not Suspicious Activity Reports (SARs). It is likely that where you are reporting a known or potential sanction breach, you will also need to lodge a SAR with the National Crime Agency. The March newsletter article provided links to guidance from the Consultative Committee of Accountancy Bodies (CCAB) and HMRC, and links to the OFSI website.