Iran Sanctions: AML and Sanctions Checks for UK Firms
In brief: Iran sanctions exposure should trigger careful screening, source-of-funds review, counterparty checks, and documented escalation where a UK firm may be asked to support restricted activity.
Key points
- Screen all relevant parties and ownership links.
- Look beyond nationality to funds, sectors, goods, services, and counterparties.
- Escalate uncertainty before acting or receiving funds.
Iran sanctions risk in client work
Iran-related client work can involve sanctions, trade restrictions, dual-use concerns, payment-route issues, source-of-funds questions, and ownership complexity. A UK firm should avoid assumptions and focus on the actual client, matter, parties, and services requested.
What to check
- Is any party designated or owned/controlled by a designated person?
- Are funds coming from or through a restricted bank or counterparty?
- Is the matter connected to restricted goods, sectors, or services?
- Does the client explanation match documents and payment routes?
- Is specialist advice required before the firm acts?
What to record
Record screening results, source-of-funds evidence, ownership checks, matter facts, escalation notes, and the decision. If the firm declines or pauses, record why.
Always check current official sources before deciding. UK firms should start with the UK sanctions list, the OFSI consolidated financial sanctions list, and the relevant GOV.UK regime pages.