Sanctions limit Russia's trust services

The UK regime is handled by OFSI (OFSI). The government imposes the measures to meet foreign policy or security goals.

Several pieces of legislation have changed the regime in recent years. SRA has produced recommendations to help firms understand their obligations.

The government has banned trust services for persons related to Russia (unless they were supplied just before the rules took effect) or a designated person. On 16 December 2022, the Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations took effect.

Paul Philip, SRA CEO, said law firms had a critical role in strengthening the financial sanctions mechanism as part of the government's reaction to war in Europe. The penalty scheme applies to all law firms, not only those covered by AML legislation. Complex and fast-moving, we released early recommendations last month. Firms should sign up for OFSI notifications to be informed and conduct necessary client checks.

"Trust services" are:

trust formation

a trust's registered office, business address, correspondence address, or administrative address

the operation or management of a trust or similar arrangement acting or arranging for another person to function as trustee of a trust or similar arrangement, where "trustee" implies a person who holds an equivalent or similar position to a trust trustee

19(A)2 defines a "Russia-connected" person. A person is connected to Russia if they live or are located there. A non-individual is related with Russia if it's incorporated or domiciled there.

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