Check frozen assets list, urges SRA

Solicitors must check the latest treasury list of frozen assets and report by 16 October if they are holding client monies subject to financial sanctions

The Solicitors Regulation Authority (SRA) has issued its annual reminder to solicitors to check the HM Treasury Consolidated List of asset freeze targets in case a client is listed, in which case they are then required to submit a report to the Office of Financial Sanctions Implementation (OFSI).

Sanctions are an important foreign policy and national security tool.

The treasury requires anyone holding or controlling funds or economic resources belonging to a designated person to report to the OFSI.

The SRA said the profession must comply with financial sanctions in place in the UK and report frozen assets and other relevant information to OFSI immediately.

This requirement is in addition to any other non-financial sanctions reporting obligations a firm or solicitor may have, such as those required by the SRA itself or submitting suspicious activity reports (SARs) to the National Crime Agency.

The SRA’s general counsel, Juliet Oliver, said: "Solicitors should be aware of their obligations under financial sanctions legislation and make sure they are not helping anyone with dubious funding streams.

“This risk exists for every single solicitor and law firm, whether conveyancing on the high street or handling global transactions.”

Stephen Baker, senior partner at Baker & Partners, said failure to ensure such sanctions regimes are properly adhered to carries the most serious reputational and regulatory risk – including the risk of criminal sanction.

He added: “In addition to complying with core UK requirements to report any assets held by individuals featuring on the HM Treasury Consolidated List of asset freeze targets, those law firms operating in other jurisdictions need to give consideration to initiatives in the UK and consider the sanction reporting obligations that may apply in the jurisdictions within which they operate - particularly where such jurisdiction largely mirrors the approach adopted by the UK, for example the Crown Dependencies.

“Law firms operating in those jurisdictions may have local sanction reporting obligations with regards anyone featuring on [the list].”