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10) Does your organisation have a compliance officer or equivalent role dedicated to financial crime, including economic and trade sanction compliance?

August 19, 2021
Financial Risk
Compliance Officer

Answer yes if your organisation has a compliance officer dedicated to maintaining your organisation's compliance with all applicable financial crime regulations, including economic and trade sanctions.

It is illegal for any entities to conduct business with individuals or entities within countries that are currently under financial and trade sanctions. Furthermore, Firms which are subject to FCA regulations have a statutory and regulatory requirement to comply with the UK sanctions regime. This covers:

  • credit institutions;
  • financial institutions;
  • auditors, insolvency practitioners, external accountants and tax advisers;
  • independent legal professionals;
  • trust or company service providers;
  • estate agents;
  • high value dealers;
  • casinos.

For firms that exist outside of the above list it is still recommended that they complete a risk assessment to highlight where they are most exposed or at risk. Effective controls and processes should be implemented to mitigate this risk.

A compliance officer is a requirement for FCA regulated firms but is not a legal requirement for firms that don't have a high risk of breaching financial or trade sanctions.

Compliance with financial rules and regulations is an important responsibility of any business. Both large and small businesses often require assistance with this, and therefore appoint a full time compliance officer.

A compliance officer is responsible for maintaining their company's compliance with regulation and legal requirements. A large part of this is maintaining compliance with sanctions requirements.

Typically the compliance officer will be responsible for the organisation's anti-money laundering framework, trade and financial sanctions compliance, and fraud framework.

How to implement the control

If your company falls in scope for trade and financial sanctions regulation it is best you seek professional external advice on how to comply with it. We'd recommend speaking to a lawyer or regulatory consultant.

If your company doesn't do business in geographies where sanctions exist, or doesn't conduct business activities that are considered high risk (such as financial services), then you may not need to implement any sanctions controls.

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