New SRA Sanctions Guidance (Nov 22)
Late in 2022 the SRA issued guidance on the sanctions regime, which has been thrown into sharp focus since the Russian attacks on Ukraine. A niche subject area, the Guidance reminds us that sanctions have nothing to do with anti-money laundering procedures and require us to cheack all clients, counterparties and other third parties to ensure that they are not designated persons. In a fast changing environemrent, what steps do we need to take to ensure compliance?
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