CQS AML Policy

  • Sanctions risk assessment: What is involved?

    Is is considered best practice to align a firm-wide sanctions risk assessment with the requirements of the MLR2017. These regulations outline several risk factors that should be taken into account. They include: Screening technology is part of the sanctions risk A sanctions risk policy should also consider the systems used to identify designated persons. It…

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  • Sanctions regime – Why firmwide risk assessments are a must

    Updated October 2026: This article has been revised to reflect current SRA guidance, the UK Sanctions List and the practical lessons arising from recent OFSI enforcement action. The UK sanctions regime applies to every law firm—not only practices acting for international or high-net-worth clients. A firm-wide sanctions risk assessment helps a practice identify where it…

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