Key takeaways from the assessment include:
➡️ 7% of all reported breaches involved property and related services firms in some capacity;
➡️ It is almost certain that property and related services firms have not reported all suspected sanctions breaches to OFSI;
➡️ It is highly likely that property-related suspected breach activity associated with Russian designated persons (DPs) has been facilitated by small-firms with long standing relationships and high risk appetites.
🗓️ UK lettings agents should ensure their sanctions control and reporting frameworks are in line with the regulators expectations ahead of OFSI reporting requirements taking effect on the 14th of May.