Jurisdiction(s):
United Kingdom

Key definition

Sanctions definition

What does Sanctions mean? Sanctions are the penalties or procedural consequences a court imposes in civil litigation when a party fails to comply with procedural rules, practice directions or court orders. Common sanctions include striking out or dismissing a claim or defence, debarring a party from relying on evidence or experts, costs orders (including indemnity or wasted costs), stays, unless orders with automatic strike-out on non-compliance, and, in serious cases, contempt remedies. In England and Wales, sanctions are imposed under the Civil Procedure Rules (for example CPR r.3.1, r.3.4, r.3.5, r.32.10 and r.3.14). A party may seek relief from sanctions under CPR r.3.9,...

UK financial sanctions compliance for law firms: good and poor practice from OFSI, FCA and SRA across governance, risk assessment, CDD, screening, escalation, reporting, policies and training

Published by a LexisNexis Risk & Compliance expert

Practice notes

The financial conduct authority (FCA) sets out examples of effective practice for sanctions frameworks and controls in Part 7 of its FCG: A firm’s guide to countering financial crime risks, and in its Financial Crime Thematic Reviews (FCTR) Part 8 on financial services firms’ approach to UK financial sanctions. This Practice Note draws on those sources. It also reflects guidance issued by the SRA for law firms on complying with the UK Sanctions Regime, together with insights from its anti-money laundering annual reports. Our Financial sanctions compliance—checklist highlights particular Precedents you can use or tailor to evidence sound practice in financial sanctions compliance.

Governance and senior management responsibility

Good practice

A suitably senior individual oversees the firm’s compliance with the sanctions regime.
Clear articulation of when customer screening occurs in different scenarios, eg when clients are transferred by agents or other companies within the group.
Appropriate escalation of confirmed target matches, potential matches that are not readily verifiable, and any sanctions breaches.
Notifications are made promptly.
Senior management approves and takes responsibility for policies...

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Web page updated on 22/05/2026

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