Regulatory implications of sanctions

Since the Russian invasion of Ukraine the UK and its international partners have imposed an unprecedented number of sanctions on Russia. The Financial Conduct Authority (FCA) has emphasised to regulated firms the importance of ensuring that they are acting in compliance with the UK’s sanctions requirements and has warned firms and their senior managers of the regulatory consequences of failing to do so. This Legalease article provides a brief overview of the FCA’s expectations for regulated firms in relation to sanctions compliance.

What is the role of the FCA?

The FCA does not enforce sanctions rather it has responsibility for ensuring that firms within its supervisory scope have adequate policies procedures systems and controls necessary to comply with UK sanctions requirements. The FCA expects firms to comply with the UK’s financial sanctions framework including with the asset freezing regime and...