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The latest paragraphs for you to consider including in your CQS CPMS Policy.

Text for CQS CPMS Policy

CQS Policy: Sanctions (update)

Change date
Word count
157
Deployment measure
9/10
Rationale

Since January 28, 2026, the UK has moved to a Single Sanctions List. Your FWRA needs to reflect this shift and address the SRA’s heightened focus on "ownership and control. Whist some firms have updated their AML policy, don’t forget to update your FWRA

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