OFSI Publishes Legal Services Sector Threat Assessment

The assessment provides information on suspected sanctions breaches and aims to assist stakeholders in their risk-based approach to compliance.

Key takeaways include:

➡️ Since February 2022 the legal services sector has submitted the second highest number of suspected breach reports;

➡️ It is highly likely that trust and company service providers (TCSPs) have not disclosed all suspected breaches to OFSI; and

➡️ It is almost certain that Russian designated persons (DPs) are using complex corporate structures to obfuscate ownership and control of assets that could be frozen under UK financial sanctions.

✅ Legal services firms should embed the assessment’s findings into their sanctions risk assessments and due diligence procedures to ensure compliance amid an increasingly complex and evolving threat landscape.