It is more important than ever to ensure compliance with the sanctions regime, as well as the anti-money laundering obligations, to avoid unintended consequences.

Every law firm is potentially at risk, particularly given that anyone subject to sanctions (‘designated persons’) is considered likely to attempt to circumvent sanctions. It stands to reason that there will be some law firms at greater risk of being ‘used’ for those purposes, particular higher risk boutique firms.

Remember that the sanctions regime operates under strict liability, so even unintentional breaches can lead to financial and other adverse consequences.

UK Sanctions

UK sanctions (restrictive measures) include director disqualification, financial sanctions, trade sanctions and travel bans. Sanctions are issued under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA); and associated regulations which impose different types of sanctions depending on the individual or entity, and the purpose of the sanction.

It is important to be aware of new regulations when issued. For example, in May 2026 new powers enabling the government to implement sanctions end-use controls (the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026). These are powers aimed at tackling the circumvention of trade sanctions, particularly where goods or related activity may be at risk of being used in ways that would undermine UK sanctions through their end use/end user.

The UK sanctions lists was most recently amended on 14 July 2026, listing all those under sanctions and why.

Compliance

All firms in all sectors (even unregulated firms) must comply with the sanctions regime (see Sanctions and Money Laundering Act 2018) – it’s not just a small proportion of firms as it once was.

How firms are to comply is not prescribed (unlike the wider AML regime). Solicitors and all firms will therefore particularly welcome the SRA’s guidance on complying with the UK sanctions regime which reinforces what’s expected of law firms and solicitors. (This was updated in January 2026.) The SRA makes clear that it will have regard to this guidance when exercising its regulatory functions.

The SRA states that while it is not compulsory to have a sanctions risk assessment, it is best practice. Best practice will, it adds, mirror the requirements of the MLR 2017.

Thorough due diligence on all relevant parties will at the very least be necessary. The firm’s responsibility when onboarding clients is to carry out appropriate checks on clients, and others in the supply chain (such as vendors and other business partners), to ascertain their designation status.

Your practice’s ongoing monitoring processes must also be effective, understanding what you will need to consider before acting (or continuing to act) for a client who is on the sanctions list.

For an in depth look at the sanctions regime and how law firms should respond book the LAW2026 SRA Webinar Bundle presented by Trevor Hellawell.