Text for CQS CPMS Policy
CQS Policy: Licensing requirements (update)
Purchase this policy: Sanctions Policy
- Change date
- 12/10/2026
- Word count
- 93
- Deployment measure
- 9/10
Rationale
This update clarifies when sanctions authorisation is required for legal services, payments and the underlying transaction. It distinguishes financial sanctions licensing from trade sanctions licensing and explains why an OFSI licence does not authorise otherwise prohibited trade activity.
Before undertaking work involving a designated person, the MLRO must determine whether the proposed services, payments and underlying transaction are permitted. Providing legal advice is not automatically prohibited by an
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