A message from the Bar Standards Board in reference to the Russian invasion of Ukraine

As you are no doubt aware, the government has recently extended the range of sanctions that are in place (and it continues to do so) in response to the Russian invasion of Ukraine. I am writing to you to raise awareness of the sanctions regime and the role that barristers have in ensuring that those sanctions are effective. 

All barristers and BSB entities must have procedures in place to enable them to comply with sanctions. Information about this is available on our website: https://www.barstandardsboard.org.uk/for-barristers/compliance-with-your-obligations/sanctions.html

and on the Government’s website: https://www.gov.uk/government/publications/financial-sanctions-faqs

There are some exemptions for which you can seek a licence from the Office of Financial Sanctions Implementation (OFSI). These include applying for a licence in order to receive reasonable fees for the provision of legal advice. OFSI will judge whether the fees are reasonable. See this page for further information on obtaining a licence: https://www.gov.uk/guidance/licences-that-allow-activity-prohibited-by-financial-sanctions 

In addition, independent legal professionals are subject to certain reporting obligations. You must inform OFSI promptly if you know or reasonably suspect that a person is a designated person or has committed offences under sanctions regulations, where that information is received in the course of carrying on business (this is explained in the OFI guidance linked above). 

We are asking you to publicise this information with your members, if you have not done so already. Both the Legal Services Board and the Office for Professional Body Anti-Money Laundering Supervision (our oversight regulator in relation to the Money Laundering Regulations) have asked us to tell them what action has been taken, therefore we would be grateful if you could confirm to us when you have done this, and if you have taken any other action to promote compliance. Please do this by emailing us at: supervision@barstandardsboard.org.uk 

If you have any questions about this email or about the sanctions regime, please feel free to contact us by emailing supervision@barstandardsboard.org.uk

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