Sanctions Compliance Policy Writers

What are Sanctions Compliance Policies?

Sanctions compliance policies outline how organisations ensure that their business activities, transactions and relationships comply with international, national and regional sanctions regimes.

Sanctions breaches can result in severe legal, financial and reputational consequences.

A clear policy ensures that employees, contractors and partners understand their responsibilities and that robust checks are in place to prevent dealings with sanctioned individuals, entities or countries.

What Do Sanctions Compliance Policies Cover?

A sanctions compliance policy typically includes:

• A statement of commitment to comply with all applicable sanctions laws and regulations

• Procedures for screening customers, suppliers and business partners against sanctions lists

• Responsibilities of employees and managers in carrying out due diligence

• Risk assessments of transactions, jurisdictions and counterparties

• Escalation and reporting processes for potential sanctions matches

• Record-keeping requirements for due diligence and screening activities

• Training and awareness for staff on sanctions risks and compliance obligations

• Cooperation with regulators and law enforcement agencies where required

• Links to anti-money laundering, anti-bribery and corruption, conflicts of interest and procurement policies

A clear policy helps ensure that all staff understand the importance of sanctions compliance and the procedures in place to manage risks.

It also supports compliance with UK regulations, including those administered by the Office of Financial Sanctions Implementation (OFSI), as well as international frameworks such as UN and EU sanctions regimes.

By embedding sanctions compliance into business practices, organisations can reduce legal and reputational risks, protect global operations and demonstrate their commitment to responsible and lawful conduct.

Legal Basis

The UK sanctions regime sits under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA), enforced by the Office of Financial Sanctions Implementation (OFSI) within HM Treasury.

OFSI has used its civil monetary penalty powers extensively since 2022, particularly on Russia and Belarus regimes.

Strict liability now applies to many breaches, with maximum penalties of the higher of £1 million or 50% of the breach value. OFSI also publishes detailed sectoral guidance (legal services, maritime, art market, crypto).

Common Compliance Pitfalls

• Sanctions screening on customers but not on counterparties, beneficiaries, owners or shippers.
• List updates fetched manually rather than via an automated feed.
• Frozen-asset reporting overlooked (separate to the breach itself).
• Voluntary self-disclosure framing missed, losing the ~50% penalty discount.
• No documented sanctions risk assessment per OFSI's "Threat Assessment" guidance.

What Policy Pros Delivers

Our Sanctions Compliance Policy package includes the main policy, a sanctions risk assessment, a screening procedure across customers, owners, counterparties and shippers, a frozen-asset reporting procedure, a licensing application template, and an OFSI voluntary disclosure procedure.