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SRA releases new sanctions questionnaire

The Solicitors Regulation Authority (SRA) has released a new questionnaire compelling law firms to report on their firm’s approach to financial sanctions.

The assessment should outline how the firm is ensuring compliance with the current financial sanctions regime. The window for responses is 2nd – 31st May 2023.

Below is the SRA’s guidance related to the questionnaire.

Who needs to complete a return?

All SRA-regulated firms who were not previously required to provide a return as part of our 2022 anti-money laundering information exercise must take part in this exercise.

If this includes you, we will be emailing your Compliance Officer for Legal Practice (COLP) or Authorised Signatory at the start of May with further instructions.

If you are a role holder at more than one firm you will be required to complete a separate return for each.

Do I need to provide this information?

Yes. We will be requesting this information under paragraph 3.3 of our Code of Conduct for Firms. There are no exceptions to the requirement to do this. We may take action against those that fail to submit the information within the required timetable.

Once the window is open, we will send you a dedicated link which you can use to provide your firm’s information. Responses submitted by email or post cannot be acknowledged or processed.

What will I be asked?

To help you prepare the questions are listed below (along with a PDF version). If you are unsure about any of the questions then please provide the most accurate answer to the best of your knowledge.

Questions that show how you are meeting sanctions requirements

Why does the SRA need this information?

The UK financial sanctions regime is operated by the Office of Financial Sanctions Implementation (OFSI). The measures are imposed by the Government to achieve specific foreign policy or national security objectives. Strengthening the financial sanctions regime is an important part of the government’s response to war in Europe.

All SRA-regulated firms must ensure they comply with sanctions legislation, including ensuring they are not receiving fees for work for a designated person outside of a licence from OFSI. Breaching such requirements can result in criminal prosecution or a fine.

To help us assess risk within the sector we require all SRA-regulated firms to provide certain information regarding their approach and potential exposure to financial sanctions risk.

What will you do with this information?

We will use the information you provide to help us assess potential financial sanctions risk faced by your firm, and by SRA-regulated firms overall.

What are sanctions?

Sanctions are restrictive measures that can be put in place to fulfil a range of purposes. In the UK, these include complying with UN and other international obligations, supporting foreign policy and national security objectives, as well as maintaining international peace and security, and preventing terrorism.

Financial sanctions include restrictions on designated persons, such as freezing their financial assets, as well as wider restrictions on investment and financial services.

If you have any queries regarding whether you are in scope, contact our Professional ethics helpline.

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