The CCAB has issued a joint statement to the profession following recent and on-going developments in Ukraine.
Office for Professional Body AML Supervision guidance
In light of the government’s response to the situation in Russia and Ukraine, we have received the below communication from OPBAS. Where relevant, AML supervised firms should consider this as part of their general risk assessment process and established systems and controls to counter anti-money laundering and terrorist financing:
I am writing to draw your attention to the tranche of sanctions imposed by the UK on Russia, following the Prime Minister’s announcement to the House of Commons on 22 February 2022. The full details of the measures are available on the Foreign, Commonwealth & Development Office website.
Professional firms and relevant practitioners will be legally required to adhere to these sanctions to safeguard the UK and the reputation of their industries. 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. Details of their enforcement approach is available on OFSI’s website.
OPBAS would like to draw the PBSs’ attention to a statement published by the Financial Conduct Authority (FCA) in response to the sanctions. The statement reminds the FCA’s supervised populations of its expectations around sanctions.
OPBAS encourages PBSs similarly to share relevant information with their own supervised populations to help remind them and ensure compliance with these new sanctions.