UK financial sanctions compliance for FCA and PRA regulated firms: obligations, systems and controls, guidance, reporting, enforcement and AML/CTF links

Published by a LexisNexis Financial Services expert

Practice notes

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This Practice Note sets out the UK financial sanctions legal and regulatory framework as it applies to firms regulated by the Financial Conduct Authority (FCA) under the Financial Services and Markets Act 2000 (FSMA 2000), and to firms within the FCA’s supervisory scope, such as e-money and payment firms (collectively, firms).

It outlines the FCA and Prudential Regulation Authority (PRA) regulatory requirements for firms and senior management concerning sanctions. It also explores the interplay between the anti-money laundering (AML)/counter-terrorist financing (CTF) framework and sanctions compliance, and the FCA and Joint Money Laundering Steering Group (JMLSG) guidance on sanctions compliance, including the scope and status of that guidance.

Key points

Firms have legal and regulatory duties to put in place, and maintain, robust defences and risk management frameworks that identify and mitigate financial crime risk, including sanctions risk
The FCA does not make, implement or enforce financial sanctions; instead, it ensures firms within its supervisory scope have adequate systems and controls to comply with UK sanctions requirements
Guidance issued by the FCA and the JMLSG is relevant to meeting regulatory requirements...

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Web page updated on 26/05/2026

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