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Makes available the latest paragraphs for you to consider including in your CQS CPMS Policy.
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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