Trade Sanctions: AML and Client Risk Guide
In brief: Trade sanctions restrict certain goods, services, sectors, or dealings, and they can affect professional firms when client work touches sanctioned activity.
Key points
- Trade sanctions are not limited to banks or exporters.
- Accountants and law firms should watch for clients, goods, services, sectors, and counterparties linked to restricted activity.
- The AML file should record what was checked and why the firm could continue.
What are trade sanctions?
Trade sanctions restrict certain goods, services, sectors, countries, or types of dealing. They may affect exports, imports, technical assistance, brokering, financing, insurance, legal work, accounting support, or company services depending on the regime.
Why professional firms should care
A firm may not ship goods, but it may advise, account for, structure, finance, or document client activity. That can create exposure if the client operates in restricted sectors or jurisdictions.
Questions to ask
- What goods or services are involved?
- Which countries, counterparties, vessels, or sectors are connected?
- Is the client asking the firm to support a restricted transaction?
- Does the work require specialist sanctions advice?
- What evidence supports the decision?
Evidence record
Record the client explanation, countries involved, counterparties, screening results, source documents, advice obtained, and the decision.
This guide is general information for UK regulated firms. Sanctions change quickly, so always check the relevant official list or get specialist advice before making a client decision.