UK solicitors’ regulator updates guidance on sanctions & EWRA
05/02/2026
The UK’s Solicitors Regulation Authority (SRA) has updated its guidance on
- Complying with the UK sanctions regime - https://www.sra.org.uk/solicitors/guidance/financial-sanctions-regime/ and
- It's firm-wide risk assessment guidance.- https://www.sra.org.uk/solicitors/guidance/sanctions-regime-firm-wide-risk-assessments/
Complying with the UK sanctions regime
The updated guidance:
- Adds a case study to illustrate how SRA-regulated firms may inadvertently become involved in the sanctions regime, i.e.
- Firms that are unwittingly providing services or funds to a UK-sanctioned person/entity, or
- In any other way breaching the legislation and fulfilling the associated reporting obligations.
- Updates red flag guidance to include self-reporting responsibilities and the need to screen staff during onboarding.
- Outlines when firms must report sanctions issues to the SRA in addition to the UK Office of Financial Sanctions Information. This includes
- Failing to meet reporting deadlines while using a general license, or
- Accepting and forwarding payments from designated persons outside the terms permitted by a general license.
- Guides licensing.
Firm-wide risk assessments
- This guidance is aimed at helping firms assess exposure to risks associated with UK sanctions.
- The guidance provides tips for
- Completing risk assessment and
- Includes a matrix of good and bad practices for specific sanctions risks.
SOURCES
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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.