Since our March 2022 Risk Update, there has been much activity in relation to Ukraine and Russia with many names added to sanctions lists almost daily, highlighting the need to screen clients on an ongoing basis and to understand precisely the checks which electronic service providers are making. The Economic Crime (Transparency and Enforcement) Act 2022 introduces a ‘strict civil liability’ test for monetary penalties. The Law Society has published guidance on this and other measures in the Act.

The Office of Financial Sanctions Implementation (OFSI) updated its Russia guidance in line with the current and emerging circum-stances of Russia’s invasion of Ukraine, and its general guidance by adding a paragraph to Chapter 4 on ownership and control and its approach to the aggregation of different designated persons’ holdings in a company.

The Financial Conduct Authority published a statement on Events in Ukraine – impact on financial markets, with a warning of insider dealing risk issues.

The United Arab Emirates (UAE) has been added to the Financial Act Task Force (FATF) grey list – of some significance as wealthy Russians are reported to be moving their money and activities there.

FATF has published a Public Consultation on its Risk-Based Guidance to the Real Estate Sector.

Links to documents mentioned above are on A link to an article by Frank Maher in New Law Journal, Russian sanctions compliance: the Devil no longer wears Prada, is on

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