Cross-government review of sanctions implementation and enforcement

The government has published its strategic approach to enforcing breaches of UK financial sanctions. The guidance outlines the government’s enforcement priorities, key enforcement principles, and the potential consequences of non-compliance.

The cross-government review emphasises the importance of maintaining effective sanctions compliance frameworks and explains the respective roles of government departments, regulators, supervisory authorities and enforcement agencies. It also includes guidance on licensing arrangements and reporting routes across the various UK sanctions regimes.

The Faculty Office encourages all notaries to review the sections relating to the risk-based approach to enforcement, particularly the guidance on mitigating and aggravating factors in civil enforcement cases. Appropriate due diligence measures, effective sanctions controls, and timely voluntary disclosures may be taken into account when assessing potential breaches.