UK sanctions compliance systems for legal practitioners: risk assessment, due diligence and screening, OFSI reporting and licences, breach management, training, record-keeping and senior management oversight

Published by a LexisNexis Risk & Compliance expert

Practice notes

This Practice Note offers advice on setting up systems and controls to meet obligations under the UK sanctions framework. It excludes systems and controls for organisations providing sanctions-related services, e.g. contesting designation decisions, which demand specialised skills and expertise.

Your systems and controls

There are several actions to take when creating your systems and controls. You should:

evaluate your potential exposure to sanctions restrictions, i.e. carry out an organisation-wide risk assessment
use the findings to design and implement suitable policies and procedures, covering due diligence, screening against sanctions lists, and steps to follow if a designated person is identified, etc
keep appropriate records of sanctions compliance, including the organisation-wide risk assessment, per customer/matter risk assessments, policies and procedures, and investigations into possible matches, etc
train staff on the sanctions framework and your internal procedures
regularly review your systems and controls
report regularly to senior management on the sanctions risks faced and the effectiveness of your systems and controls

Assess the risk

Although there is no legal requirement to...

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Web page updated on 22/05/2026

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