Check for any individuals on the sanctions list
Firms that have been asked to set up new companies for overseas clients generally or those that may need to be listed on the Register of Overseas Entities should ensure that they have checked the UK Sanctions list to ensure they are not failing to adhere to any sanctions. In particular, they must check and ensure that any directors or shareholders of such companies are not sanctioned. Where there is a failure to adhere to the sanctions, the Office of Financial Sanctions Implementation (OFSI) has the power to levy civil monetary penalties for breaches of financial sanctions. OFSI works with law enforcement for the most egregious cases where criminal prosecution may be considered.
Our anti-money laundering hub provides guidance on reporting obligations and contains links to the Sanctions List as well as guidance on your obligations to report any breaches of financial sanctions.