UK financial sanctions in relation to Russia

Read ACCA's expectations and requirements of members concerning the Russian invasion of Ukraine

Following the UK Prime Minister’s announcements to the House of Commons on 22 February 2022 and 24 February 2022, the UK has announced a tranche of sanctions on Russia. Details of all measures are available on the Foreign, Commonwealth & Development Office website.

ACCA expects UK firms to have established systems and controls to counter the risk that they might be used to further economic crime, including compliance with financial sanctions obligations.

Our expectations of firms’ systems and controls in relation to compliance with financial sanctions are set out in the Anti-Money Laundering and Counter-Terrorist Financing Guidance for the Accountancy Sector (AMLGAS) section 5.3.24 to 5.3.25.

Firms should follow their risk-based approach on how they screen current and new clients against the UK Sanctions List to meet these new sanctions measures and screen against the Office of Financial Sanctions Implementation (OFSI) list of asset freeze targets for financial sanctions obligations.

You are legally obliged to report to OFSI if you know or suspect that a breach of financial sanctions has occurred; if a person you are dealing with, directly or indirectly, is a designated person; if you hold any frozen assets; and if knowledge or suspicion of these come to you while conducting your business. You must contact OFSI at the earliest opportunity.

Where clients give rise to concerns about sanctions evasion or money laundering, you should also consider your obligations to report to the UK Financial Intelligence Unit (UKFIU) at the National Crime Agency (NCA) under the Proceeds of Crime Act 2002.

For further details on financial sanctions you should contact OFSI or, for trade and export sanctions, the Department for International Trade’s Export Control Joint Unit.

If you require a licence to permit any activity that would otherwise be prohibited by sanctions regulations, you must contact the relevant department.

Applications must be made in advance of any business agreement or transaction taking place.

Firms should be aware that these sanctions are subject to change and should maintain up-to-date screening processes.

Guidance and supporting tools to help with the risk assessment of clients are available on ACCA’s UK Technical pages.