The UK’s Financial Conduct Authority (FCA) plays a key role in monitoring how UK-regulated financial institutions guard against financial crime risks, and how effectively they implement financial crime policies and procedures. In recent months, as the UK and other governments have placed increasing focus on preventing the circumvention of sanctions targeting Russia, the FCA has taken a number of steps to emphasise its focus on how financial institutions are complying with financial and trade sanctions, in light of the roles of financial institutions in facilitating global trade and in enabling the flow of funds into capital markets.  

In this briefing, we have provided a summary of key steps that the FCA has taken to ensure that financial institutions are complying effectively with financial and trade sanctions, as discussed in the FCA’s recent Annual Report 2022/23. We have also provided a summary of key sanctions compliance risk mitigation steps for financial institutions to consider going forward.

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Tristan is a Partner at Baker McKenzie, advising clients on sanctions and export controls, anti-bribery and corruption and other corporate compliance risks. He provides compliance advice to clients across these risk areas, including in the context of complex cross-border transactions, as well as supporting clients in the management of related internal and external investigations. Tristan is the UK head of Baker McKenzie’s market leading international trade practice, which is ranked as Tier 1 by Legal 500 and Band 1 by Chambers UK. He is personally ranked as a Leading Individual for ‘Trade, WTO, Anti-dumping and Customs’ by Legal 500 and Band 3 for ‘Sanctions’ by Chambers UK. He is the EMEA Chair of the firm's Investigations, Compliance & Ethics practice.

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Sven Bates is Of Counsel for International Trade at Baker McKenzie. He has spent the majority of his career at the Firm's London office, focusing on international trade compliance, trade remedies and anti-bribery. He has also practiced in Amsterdam and has previously worked for the European Commission and the Shadow Attorney General. Sven has extensive experience in particular in the financial services sector, and has undertaken secondments at a Tier 1 UK bank and the Lloyd's insurance market.

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Julian Godfray is a senior associate in Baker McKenzie's market-leading International Trade and Compliance & Investigations practices, and is based in London. Julian joined Baker McKenzie as a trainee in September 2014, and qualified in September 2016. Julian has been seconded to two FTSE 100 clients during his time at Baker McKenzie, including in the ethics and compliance team of one client. Julian has also been seconded to the sanctions legal team of a major global investment bank. Julian has also completed secondments to Baker McKenzie's Brussels office in 2016, and more recently to the firm's Madrid office, working as part of the firm's trade compliance practice in Spain.