The SRA published a news release on 23 February 2022, warning that all SRA-regulated firms must have appropriate policies in place to ensure they comply with sanctions legislation, including undertaking regular and appropriate checks of sanctions lists.

The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2022, in force from 10 February 2022, amend the designation criteria of The Russia (Sanctions) (EU Exit) Regulations 2019. Designation criteria now include those who have been involved in obtaining a benefit from or supporting the Government of Russia.  (Links to both documents are on

With almost daily additions to sanctions lists, firms which are more exposed to higher risk clients will need to consider electronic monitoring of not only client lists but also counterparties.  They should also check how often the providers update the electronic checks, the data sources and use of filters and fuzzy matching.

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