EU regulation extends scope of sanctions reporting to lawyers and others in the UK

On 8 August, a new EU regulation will come into force in the United Kingdom, which will make it an offence for certain businesses and professions to fail to report to HM Treasury if they ‘know or have reasonable cause to suspect that a person has committed an offence under the relevant [financial sanctions] regulations or is a person who is the subject of an asset freeze.’

An explanatory memorandum reads:

‘Currently the United Kingdom’s enforcement of financial sanctions measures backed by criminal law only require a “relevant institution” to report to HM Treasury, with “relevant institution” defined in such a way as to effectively apply to only financial institutions.

‘This statutory instrument extends the organisations to which the domestic legislation and associated criminal law applies to include other businesses or professions to ensure the United Kingdom meets best practices set by the Financial Action Task Force. Those businesses and professions affected include: independent legal professionals, trust or company service providers, estate agents, dealers in precious metals and stones, casinos, accountants and others.’

The explanatory memorandum to the regulations can be found here:
http://www.legislation.gov.uk/uksi/2017/754/pdfs/uksiem_20170754_en.pdf

The European Union Financial Sanctions (Amendment of Information Provisions) Regulations 2017 can be found here:
http://www.legislation.gov.uk/uksi/2017/754/pdfs/uksi_20170754_en.pdf