United Kingdom: The SRA Strengthens Its Guidelines on Sanctions

On February 4, 2026, the UK Solicitors Regulation Authority published an update to its guidelines on compliance with the UK sanctions regime and on firm-wide risk assessment. This development reflects the growing focus on compliance obligations in regulated professions, particularly against the backdrop of strengthened sanctions regimes.

The new guidance emphasizes, in particular, the risk of unintentional involvement in sanctions violations. The authorities note that legal professionals may be exposed to these risks in the course of their work, even without direct intent, underscoring the need to implement robust internal controls.

The updated framework also emphasizes the identification of warning signs. Self-reporting requirements have been clarified, as has the importance of conducting thorough background checks on staff upon their hiring. These measures aim to strengthen risk prevention and more effectively detect any high-risk situations.

Furthermore, the SRA specifies the cases in which incidents must be reported, not only to the regulatory authority itself, but also to the Office of Financial Sanctions Implementation. This dual requirement underscores the increased coordination among authorities regarding sanctions.

Clarifications have also been provided regarding the use of licenses, to help professionals better understand under what conditions certain transactions may be authorized despite existing restrictions.

This update confirms that managing sanctions-related risk is now a key priority for regulated professions. It requires heightened vigilance, the establishment of internal procedures, and the full integration of compliance requirements into daily practices.