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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: Recent updates 2025

Change Date : 24/07/2025    |    Word Count: 200    |    Deployment Measure : 9/10
9/10
Rationale: Provisional wording noting OFSI’s April 2025 warning on the misuse of trusts and complex structures by Russian DPs, often involving family members or associates. Also reflects underreporting concerns by TCSPs and recent UK/EU sanctions on Russia’s shadow fleet and financial institutions, reinforcing the need for strict scrutiny and reporting.
OFSI published a threat assessment for the legal services sector in April 2025 which identified that there has been, “…widespread misuse of complex structures and trusts to hide asset ownership …


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