Russia Sanctions: Practical Checks for UK Firms
Certivus AML team7 minUpdated 2026-06-27
In brief: Russia sanctions exposure can arise through direct designations, ownership or control, services, sectors, funds, counterparties, and client attempts to restructure around restrictions.
Key points
- Check ownership and control, not just the client's trading name.
- Review payment routes, source of funds, and services requested.
- Keep a clear decision record for every possible match or escalation.
Russia sanctions risk in UK AML files
Russia sanctions work is rarely just a name search. A client may not appear on a list, but ownership, control, sector exposure, services, funds, or counterparties may still create risk.
Practical review points
- Screen the client, beneficial owners, directors, and controllers.
- Check ownership chains for designated persons.
- Understand whether the service itself is restricted.
- Review source of funds and source of wealth where relevant.
- Watch for sudden ownership changes, nominee arrangements, or unusual urgency.
Evidence to keep
Keep source list, search date, match-review notes, ownership chart, funds evidence, advice obtained, and the firm's decision.
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.