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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