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Can I Do It Myself?

Yes you can!

You will find the sanctions list on the HM Treasury web site by clicking here.

However before you do think, can I demonstrate that my client is not on the list? Whilst it is very easy to download this list and equally easy to search it once done, there is absolutely no record of your search. Your regulator is not looking for you to search the list. Instead they will be looking for you demonstrate your client is not on it. You can only do that with the type of evidence found within

Furthermore we find that the list is updated frequently some weeks it has been known to update daily. There have been 27 sanctions list updates between February and March alone, so you will need to ensure that you have the new list as and when it comes out and screen all your client data against that new list.

Remember guidance not only states that you have to demonstrate your client is not on the list now, you also have to ensure and again evidence they are not on the list going into the future. This means you will have to keep checking all your clients after each and every update to ensure compliance. Should you do this you still have the burden of evidencing your clients are not on the list i.e. you need an audit trail.

This is not a trick to get you to pay for something you can do yourself, the fact is for as little as £20 per annum it just isn’t worth doing it for free, is it?

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