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Checklist The Office of Financial Sanctions Implementation (OFSI), a part of HM Treasury, is responsible for communicating, implementing and enforcing financial sanctions in the UK. It also holds powers to grant licences that permit an activity or transaction which would otherwise be prohibited under the UK financial sanctions regime. OFSI may only issue licences connected to financial sanctions. If your application concerns a different sanction, such as trade or immigration, you must send it to the appropriate Department. See further Practice Note: Understanding the financial sanctions regime. This Checklist brings together the requirements for applying to OFSI for a financial sanctions licence, alongside recommendations to help make your application faster and easier. These are drawn from multiple sources, including the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018) and regulations made under it, various OFSI guidance materials, and guidance from the Solicitors Regulation Authority (SRA). This Checklist also signposts relevant content to support compliance with these requirements and suggestions. A section is provided for you to indicate completion...
This timeline charts activity from 1 January 2024 onwards concerning the EU-facing legal and supervisory frameworks for anti-money laundering (AML), counter-terrorist financing (CTF) and counter‑proliferation financing (CPF) within the financial services sector. It traces both milestones and roll-out of the European AML, CTF and CPF rulebook. It also tracks cross-border initiatives in AML/CTF/CPF from the Financial Action Task Force (FATF), Basel Committee on Banking Supervision (BCBS), International Association of Insurance Supervisors (IAIS), IOSCO, the Egmont Group of Financial Intelligence Units (FIUs) and the Wolfsberg Group. For added detail on the EU AML/CTF regime, consult the Financial crime and sanctions (EU Law)—overview, including Practice Notes on AMLA—direct oversight of qualifying financial services firms, the EU Sixth Money Laundering Directive (MLD6) and the EU Recast Second Wire Transfer Regulation (Recast WTR2) on cryptoasset transfers... 2026 16 March 2026 — AMLA — AMLA starts a data collection exercise to test risk assessment models. AMLA has issued the reporting package for this data collection and testing exercise...
This checklist is intended to guide you if you need to close your firm. Read it alongside subtopic: Firm closure plan, particularly Practice Note: Firm closure plan-key considerations. Plan and dates ☐ Create a firm closure plan (see Precedent: Firm closure plan). Recommended to show you can carry out an orderly wind-down of your activities, as required by the SRA-SRA Code for Firms, para 2.4. (Insert any comments you may wish to make regarding your firm’s arrangements) ☐ Allocate responsibility for the plan. Recommended. (Insert any comments you may wish to make regarding your firm’s arrangements) ☐ Set a closure date. Recommended. (Insert any comments you may wish to make regarding your firm’s arrangements) Notifications ☐ Send a completed Firm Closure Notification form to the SRA. Compulsory-SRA Code for Firms, para 2.5. (Insert any comments you may wish to make regarding your firm’s arrangements) ☐ Notify staff. Recommended. (Insert any comments you may wish to make regarding...
This Flowchart This diagram is designed to help you assess whether you meet UK residence under the second automatic residence test—the 'home' test—for a tax year hereinafter referred to as 'year X'...
This Flowchart It outlines the competent authorities tasked with implementing UN and UK sanctions pursuant to the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018) within the United Kingdom jurisdiction...
Checklist This checklist outlines the principal matters to consider when preparing or assessing an outsourcing agreement. It addresses central legal, regulatory and practical questions that arise in outsourcing arrangements, while excluding sectors that carry bespoke regulatory regimes, such as health or financial services. For overarching guidance on outsourcing, consult Practice Note: Outsourcing—key terms. For discussion of negotiation points you are likely to encounter, see Practice Notes: Negotiation guide—services agreements and Negotiation guide—IT contracts. As you progress through the checklist, the third column can be used to capture observations or comments as each point is considered... Further information Notes (if any) Initial considerations What is the customer’s main reason for outsourcing? Knowing the driver—e.g. cutting costs, enhancing service quality, or obtaining a function the customer lacks the capability to deliver internally—will help. Also think about the breadth of the outsourcing, whether a service improvement mechanism is desired, and if value for money will be tested by benchmarking (see below)... Confirm whether any existing...
On 6 March 2025, the European Banking Authority (EBA) published a consultation paper setting out draft Regulatory Technical Standards (RTS). These draft RTS were issued following the European Commission’s (Commission) Call for Advice. They constitute a component of the European Union’s (EU) Anti-Money Laundering and Countering the Financing of Terrorism (AML/CTF) package, which was published in the Official Journal of the European Union on 19 June 2024...
In this issue: Key DR developments Claims and remedies Costs and funding Cross-border disputes Injunctions Civil appeals New content Dates for your diary Useful information Daily and weekly news alerts Key DR developments CPR updates 174th Practice Direction update effective 5 November 2024: The Master of the Rolls and the Parliamentary Under-Secretary of State for Justice have authorised the 174th Practice Direction (PD) update to the Civil Procedure Rules (CPR). The changes take effect at 11am on 5 November 2024. This PD update amends CPR PD 51ZE (Small Claims Track Automatic Referral to Mediation Pilot Scheme) and CPR PD 51R (Online Civil Money Claims (OCMC) Pilot Scheme), expanding the obligation to engage in integrated mediation in civil matters to money claims submitted via the OCMC service. For more information, see: LNB News 22/10/2024 127—174th Practice Direction update—in force 5 November 2024. Court guidance Damages Claims Pilot under CPR PD 51ZB—updated guidance:...
In this issue A review of key cases in 2025 Decision to prosecute and alternatives to prosecution Criminal procedure and evidence Proceeds of crime Bribery, corruption, sanctions and export controls Environmental offences Financial services and pensions offences Health and safety and corporate manslaughter offences Local authority prosecutions Money laundering Daily and weekly news alerts New and updated content Dates for your diary Trackers Useful information A review of key cases in 2025 Headline corporate crime matters in 2025 included the UK Supreme Court overturning the convictions of two traders jailed for rate manipulation; the anti-fraud agency deploying a seldom‑used legal power to recover criminal cash; and the first conviction for sanctions breaches. See News Analysis: The biggest financial crime cases of 2025. Decision to prosecute and alternatives to prosecution SFO compliance guide highlights early remediation is key On 26 November 2025, the Serious Fraud Office (SFO)...
This Practice Note examines core aspects of the UK framework for money market funds (MMFs) that stems from Regulation (EU) 2017/1131 (the EU MMF Regulation). It also looks at suggested changes to the framework, with the Financial Conduct Authority (FCA), HM Treasury and the Bank of England (BoE) working jointly to bolster its resilience and align it with post‑Brexit regulatory objectives. For background on the EU MMF Regulation, see Practice Note: EU MMF Regulation—essentials. What is an MMF? Money market funds (MMFs) are investment funds that invest in short‑term debt instruments and so play a significant role in the short‑term financing of the economy. In particular, MMFs are open‑ended, liquid investment funds that invest in fixed income through short‑term debt, for example money market instruments issued by banks, governments or companies (including treasury bills, commercial paper and certificates of deposit) which pay interest. They therefore form an important connection between demand for, and the supply of, short‑term debt. Further information on the eligible assets of an MMF is...
This Practice Note offers a beginner’s overview of construction disputes, intended for trainee solicitors and others unfamiliar with the area. It outlines what a construction disputes lawyer does, the disputes that frequently occur on projects, and gives a primer on adjudication, dispute boards, proceedings in the Technology and Construction Court (TCC), construction arbitration and alternative dispute resolution (ADR). It also considers the nature of disputes that routinely emerge on construction projects and the role undertaken by the disputes lawyer. We suggest reading Practice Note: Construction law—new starter guide, which sets out the core principles of construction law and the characteristics of construction projects, before tackling this note. The content of this Practice Note is also available as a PowerPoint deck with speaker notes—see: Introduction to construction disputes—training materials. You might also consider Practice Note: Dispute Resolution—new starter guide, which addresses dispute resolution more broadly. The work of a construction disputes lawyer Construction lawyers handling disputes (often described as contentious or back-end practice) are typically asked to support clients...
What is a service charge? A service charge is a sum a tenant may have to pay to a landlord under a commercial lease to reimburse the landlord for services they provide in connection with the common parts and for the upkeep of the property. Commonly, this applies where multiple tenants occupy one property, for example a shopping centre, and the landlord looks after the communal parts of the building for everyone’s benefit. In most contemporary leases the tenant pays the service charge on account, before the landlord incurs the expenditure, calculated from an estimate of the next year’s costs. At the close of the accounting period a reconciliation is prepared and any shortfall or surplus is settled by or to the tenant. Sometimes, earlier forms of lease stipulate that the landlord must meet the outlay first. For more detail on service charges ordinarily charged to tenants of multi-occupied buildings by commercial landlords in Scotland, see Practice Note: Service charge and outgoing provisions in commercial leases in Scotland. ...
We must not use a client account to provide banking facilities for clients or third parties. This is a firm requirement of rule 3.3 in the SRA Accounts Rules, covering our main client account and any separately designated client accounts as well. Permitting use of our client account as a banking facility creates the risk that we could potentially facilitate money laundering or comparable offences. You must understand and adhere to our policy on anti-money laundering (AML), counter-terrorist financing (CTF), and counter-proliferation financing when taking receipt of client or office monies. This also encompasses our distinct policy on accepting cash. The SRA may levy substantial penalties for breach of rule 3.3. There need not be a risk of money laundering, or any hint of impropriety, for this to apply. A breach of rule 3.3, by itself, is enough for the SRA to impose a penalty on the firm and/or any individuals concerned. We should only accept funds into our client account where...
1 Introduction This role description and profile concerns the combined post of Deputy Money Laundering Compliance Officer (MLCO) and Deputy nominated officer (nominated officer). Any references to MLR 2017 relate to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, SI 2017/692, as amended. 2 MLCO/nominated officer role holder details Firm name [ Insert firm name ] Name of Deputy MLCO/nominated officer [ Insert name ] Reports to: MLCO/nominated officer [ Insert name of MLCO/nominated officer ] Working pattern ☐ Full time ☐ Part time Details of any additional positions within the firm [ Insert details ] Date of appointment by the firm [ Insert date ] 3 Role summary 3.1 Serve as deputy to the firm’s MLCO/nominated officer...
1 General information Person(s) carrying out the audit: [ Provide name(s) of the individual(s) undertaking the audit ] Auditor classification: ☐ Internal ☐ External Audit dates: From [ enter date ] to [ enter date ] Audit type: ☐ Organisation-wide ☐ Targeted—[ Specify exactly what was targeted, e.g. property transactions funded by cryptoassets ] Office(s) in scope: [ Provide details of the offices included in this audit ] 2 Executive summary [ Provide a concise overview of the report findings ] [ Summary of recommendations: ] Importance — Number of recommendations Critical: [ Insert number of recommendations classified as critical ] Important: [ Insert number of recommendations classified as important ] 'Housekeeping': [ Insert number of recommendations classified as ‘Housekeeping’ ] 3 Scope of audit 3.1 This audit has been undertaken to: 3.1.1 review and assess the adequacy and effectiveness of the organisation’s policies, controls...
The general rule The general rule is that when a buyer of a freehold interest enters into covenants with the seller, although the burden of restrictive obligations will in many instances bind a successor in title, positive duties requiring the covenantor to act do not run when the freehold is conveyed. A rentcharge operates as a device by which a monetary duty can pass to the successor of the initial buyer. There is no issue, as a matter of contractual privity, in imposing on the purchaser a contractual obligation to pay the seller for the supply of services relating to the land; however, matters become more intricate once the seller transfers the freehold estate to a third party. The rentcharge nonetheless entitles its holder to demand regular periodic payments of money from the owner of the freehold estate. It is not a mortgage, because it does not function as security for a debt...
When one company advances funds to another, the contractual provisions govern any restriction on repaying the loan before the ten-year period first contemplated. Should the lending company enter liquidation or administration, that circumstance, by itself, does not alter the contract’s terms. The office-holding insolvency practitioner should nevertheless review the agreement to determine whether it permits earlier repayment, or repayment on alternative terms, if the lending company goes into liquidation or administration. Although that may appear improbable, it remains possible, and the officeholder ought to explore every avenue to secure accelerated repayment of the borrowing. Absent an express clause to the contrary, the insolvency of the lender does not, of itself, accelerate the debt, and timing remains governed by the bargain. It would seem that the office-holding insolvency practitioner holds an appointment that must remain open for at least ten years before the loan can be discharged and a dividend distributed to creditors...
There are a number of points to weigh up when determining if a consumer credit agreement is regulated by the Consumer Credit Act 1974 (CCA 1974). Under the CCA 1974, s 8(1), a consumer credit agreement is described as an agreement between an individual (“the debtor”) and any other person (“the creditor”) whereby the creditor extends credit of any amount...