Text for CQS CPMS Policy
CQS Policy: Trust services
Purchase this policy: Sanctions Policy
- Change date
- 24/07/2025
- Word count
- 203
- Deployment measure
- 9/10
Rationale
Draft wording making it clear that trust services must not be provided where there’s a connection to Russia, including beneficiaries or those likely to benefit financially. The definition of “connected” is based on residence or incorporation, not nationality alone, and the restriction applies to creating, managing, or arranging trusteeship.
One of the most relevant sanctions for our practice is that there is a prohibition on providing any trust related services for the “benefit of a person connected with Russia”.
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