New European regulations came into force today, 8 August 2017, that have dramatically expanded the number of businesses who must ensure they follow UK sanctions rules. The European Union (Amendments of Information Provisions) Regulations 2017 make it a criminal offence to fail to report knowledge or reasonable cause to suspect someone is under an asset freeze, or has committed an offence under a financial sanctions regime. VinciWorks has updated their sanctions course to cover these new rules from today.
While the previous failure to report offences only extended to financial institutions, the new law covers:
- Auditors
- External accountants
- Law firms and sole practitioners
- Tax advisers
- Trust or company service providers
- Casinos
- Dealers in precious metals and stones
- Estate agents
If any one working in these businesses has a suspicion, they must make a report to the Office of Financial Sanctions Implementation, or face imprisonment of up to 12 months and / or a £5,000 fine.
Businesses affected who may never have considered sanctions before in their customer due diligence must ensure they have policies and procedures in place to identify anyone under an asset freeze (designated person) or someone who has committed a sanctions offence.
While the reporting requirements are broad, they only cover UK financial sanctions, not trade sanctions or export controls. Legal privilege also applies similar to the tipping off and failure to disclose exemptions in money laundering legislation.
VinciWorks’ Sanctions course updated according to latest regulations
VinciWorks’ comprehensive international sanctions course has been fully updated to cover the new European regulations that have come into force today. Along with a detailed introduction to sanctions, different types of sanctions in force, licensing and exemptions, plus offences and consequences of breaches, our 30 minute sanctions course has been developed with leading international law firms and is appropriate for all staff.
