As part of a set of financial sanctions, Russia can't get trust services.

The Office of Financial Sanctions Implementation is in charge of running the system in the UK (OFSI). The government puts these rules in place 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 several pieces of law. The Solicitors Regulation Authority (SRA) has already put out information to help firms make sure they know what their responsibilities are.

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 new rules went into effect. On December 16, 2022, the Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations came into effect.

Paul Philip, the head 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 system applies to all law firms, not just those caught by anti-money laundering rules. This is a complicated situation that is changing quickly, which is why we put out our first set of guidelines last month. Firms would be smart to sign up for OFSI alerts so they can stay up-to-date and also do proper checks on clients and potential clients.

The change says what "trust services" are:

the setting up of a trust or something similar

giving a trust or similar set-up a registered office, business address, correspondence address, or administrative address

the operation or management of a trust or similar arrangement; acting or making plans 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 a person to be "connected with Russia." Most of the time, a person is considered to have ties to Russia if they live there or are in Russia. A person or thing that is not a person is connected to Russia if it is set up under Russian law or has its home in Russia.

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