Lexsure’s October 2026 POLICYmonitor notification contains five suggested updates addressing sanctions licensing, lender reporting, searches supplied by others and controlled use of conveyancing portals.
The updates affect four policies: the Sanctions Policy, Dealing with Lenders Policy, Risk Management Policy, and Information Management and Security Policy.
Following our September CQS policy update, October’s notification focuses on decisions that need clear authority, documented checks and an identifiable person responsible for the next action.
Some wording also reflects issues raised by the proposed Conveyancing Protocol. The Protocol remains a consultation draft. These suggested procedures should be assessed on their merits rather than described as requirements imposed by an adopted replacement Protocol.
1. Sanctions licensing: distinguish the service, payment and transaction
The first update clarifies the assessment required before undertaking work involving a designated person.
Providing legal advice is not automatically prohibited by an asset freeze. However, the firm must separately consider whether the proposed services, payment arrangements and underlying transaction are permitted.
The suggested wording requires the MLRO to establish the applicable position and identify whether an exception, general licence or specific licence is needed. Any required specific licence must be obtained before the activity it authorises takes place.
It also distinguishes financial sanctions licensing from trade sanctions licensing. An OFSI licence does not authorise an otherwise prohibited trade activity.
The practical question: has the firm checked the activity it proposes to undertake, rather than assuming that permission to receive legal fees authorises the whole matter?
This amendment belongs in the firm’s Sanctions Policy.
2. Lender reporting: receipt is not approval
The revised lender-reporting wording strengthens the content of reports, the method of submission and the evidence retained on the file.
Fee earners should check the lender’s current instructions and use the prescribed communication channel, including a designated portal where required.
A report should identify the property and mortgage reference, explain the issue and relevant instruction, describe the material legal risks, and provide the firm’s proposed solution or recommendation. Supporting documents and any transaction deadline should be included where relevant.
The update also addresses what happens after submission. The file should retain the report, supporting documents, submission confirmation and lender’s response. Outstanding reports need monitoring, and ambiguous responses require clarification.
An automated acknowledgement, confirmation of receipt or absence of a response should not be treated as lender approval.
Before submitting the Certificate of Title, the fee earner should confirm that matters requiring resolution or authority at that stage have been addressed. Where written authority is required, the relevant transaction step must wait until it has been obtained and its conditions satisfied.
This belongs in the CQS CPMS Dealing with Lenders Policy. Lexsure’s earlier Formalities of Reporting to Lenders policy paragraph provides related background; the October notification supplies the expanded wording.
3. OFSI General Licence payments: approval, reporting and records
The second sanctions amendment replaces an expired licence reference and makes the procedure for relying on a Legal Services General Licence more explicit.
The notification identifies General Licence INT/2026/9512597, which replaced INT/2025/7323088 following its expiry in April 2026.
Before each reliance, the suggested procedure requires the MLRO to check the current licence, its validity, the designations and activities covered, and the applicable payment limits, rates and conditions.
- Obtain MLRO approval before relying on the licence.
- Record the basis for reliance in the firm’s Sanctions Register.
- Where INT/2026/9512597 is used, submit the required report and supporting documents to HM Treasury within 14 days of receiving payment.
- Identify whether Part A or Part B applies and provide the corresponding evidence.
- Retain accurate, complete and readable records for at least six years.
Time-sensitive point: the published licence is scheduled to expire at 23:59 on 28 October 2026. Firms should check for any replacement, variation, suspension or revocation before relying on it. Updating a policy reference once is not a substitute for checking the authority available when the activity occurs.
The official OFSI licence publication provides the licence and accompanying notice.
These procedures also belong in the Sanctions Policy. Permission concerning legal fees should not be treated as permission for an otherwise prohibited underlying transaction.
4. Searches supplied by others need an independent assessment
A search supplied by a seller, estate agent or portal may be useful. Its availability does not establish that it satisfies the buyer’s needs or the lender’s instructions.
The October wording introduces a documented assessment before reliance, covering:
- The search date and property and title coverage.
- Its scope, provider and terms of reliance.
- Relevant insurance arrangements.
- Acceptability under the lender’s instructions.
- The need for updated, replacement, supplementary or specialist searches.
The amendment also requires additional enquiries to be justified by the particular transaction. Standard lists should be adapted to the title, contract papers, search findings, intended use and relevant instructions.
Material inconsistencies, missing information and unresolved risks need investigation and explanation before exchange. Doubts about the adequacy of the investigation should be referred for supervision.
The practical question: can the file explain why the supplied search was suitable and what the firm did about any gaps?
This addition belongs in the CQS CPMS Risk Management Policy. Our article on putting the Risk Management Policy into practice considers the wider importance of responsibility and evidence from files.
5. Conveyancing portals: control sharing and allocate review
The final update addresses approved portals and shared digital workspaces. Before use, the firm should assess access controls, authentication, confidentiality, data protection, retention and the ability to retrieve documents and an adequate audit trail.
Before sharing information, the fee earner should verify the recipients, purpose and scope of access, obtaining and recording client authority where required.
Authority to progress a transaction should not be treated as unrestricted permission to share the complete file. Identity documents, financial evidence, privileged advice and internal AML records require a specific, justified and authorised basis for disclosure.
The suggested procedure requires documents supplied through a portal or sharing link to be downloaded and saved within seven working days, or another agreed timescale, and sooner where urgency or link expiry requires. This is a proposed firm procedure in the notification, not a universal statutory deadline.
Downloading is not substantive review. The firm should separately identify who must review the material, what action follows and which deadlines apply.
Responsibility for portal notifications, absence cover, access changes and incident escalation should also be clear.
This belongs in the CQS CPMS Information Management and Security Policy.
Turn the October notification into recorded action
The useful outcome is an implemented procedure. For each relevant amendment, record:
- The policy affected and wording adopted or adapted.
- Who approved the change and when it takes effect.
- Which staff need instructions or training.
- Who owns the resulting checks and deadlines.
- How the firm will test implementation on relevant matters.
For buyers and sellers, these controls support clearer advice, secure handling of information and fewer unresolved issues reaching exchange or completion. For the firm, they help demonstrate how a policy translates into decisions on individual files.
The next notification addresses sanctions licensing, lender reporting, searches supplied by others and controlled information sharing. Read our October 2026 CQS policy update for the five changes and links to the relevant policies.
Keep your CQS policies under active review
Lexsure’s POLICYmonitor CQS Policy Update Service provides suggested paragraphs for firms to review, adapt and incorporate into their policies where appropriate.
Review the CQS Policy Update Service →Your firm remains responsible for assessing relevance, tailoring the wording and implementing its procedures.
This article summarises Lexsure’s October 2026 POLICYmonitor notification and reflects checks made on 13 October 2026. It is not a substitute for the full wording, current sanctions licences or applicable lender instructions. The proposed Conveyancing Protocol remains a consultation draft.