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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