Because of financial sanctions, Russia can't get trust services.

The Office of Financial Sanctions Implementation runs the system in the UK (OFSI). The government takes these steps to meet certain foreign policy or national security goals.

In recent years, there have been a number of changes to the regime, which is based on a number of laws. The Solicitors Regulation Authority (SRA) has already put out information to help firms make sure they know what they have to do.

The government has now made changes that make it illegal to give trust services to people with ties to Russia or to a person on a list, unless the services were given right before the rules went into effect. On December 16, 2022, the Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022 went into effect.

Paul Philip, the CEO of the SRA, said, "Strengthening the financial sanctions regime is an important part of the government's response to war in Europe, and law firms have a key role to play." The sanctions regime applies to all firms that offer legal services, not just those that are covered by the anti-money laundering regulations. This situation is complicated and changing quickly, which is why we put out our first advice last month. Firms would do well to sign up for OFSI alerts so they can stay up-to-date and also do proper checks on clients and potential clients.

"Trust services" are defined by the amendment as:

putting together a trust or something similar

giving a trust or similar arrangement a registered office, business address, correspondence address, or administrative address

the operation or management of a trust or similar arrangement; acting as trustee or making arrangements for someone else to act as trustee of a trust or similar arrangement, where "trustee" in relation to an arrangement like a trust means a person who holds a position equivalent or similar to a trustee of a trust;

Regulation 19(A)2 says what it means for someone to be "connected with Russia." Most of the time, a person is considered to have ties to Russia if they live there or are there. A person or group that is not a single person is connected to Russia if it is set up under Russian law or has its home in Russia.

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