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Text for CQS CPMS Policy

CQS Policy: Russian sanctions circumvention

Purchase this policy: Anti-Money Laundering Policy

Change date
20/08/2026
Word count
167
Deployment measure
9/10
Rationale

Covers the OFSI/OTSI guidance on third-country routing, dual-use goods, and layered ownership structures, with a clear escalation obligation to the MLRO.

The SRA’s August 2026 Sectoral Risk Assessment specifically identifies Russian sanctions circumvention as an emerging risk for legal services providers. Since the invasion of Ukraine, a range of techniques have …

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