The following changes were made:
- Controls for all firms: New information on how firms may inadvertently become involved in a Sanctions regime;
- Red flags for attempted circumvention: Updated red flags to include self-reporting responsibilities and the need to screen staff during onboarding;
- Reporting requirements: New information on firms’ reporting requirements; and
- Licensing: Further information on staying compliant with licence responsibilities.
All SRA-regulated firms, solicitors, registered European lawyers and registered foreign lawyers are expected to review the SRA Guidance and take any appropriate action in ensuring compliance with their Financial Sanctions requirements.