The financial sanctions regime prohibits the provision of trust services to Russia.

The Office of Financial Sanctions Implementation runs the UK regime (OFSI). The government imposes the measures in order to attain specific foreign policy or national security goals.

In recent years, there have been a number of changes to the regime, which is supported by various pieces of legislation. The Solicitors Regulation Authority (SRA) has already issued instructions to firms to ensure they are aware of their responsibilities.

The government has now amended the regulations to prohibit the provision of trust services to people related to Russia (unless the services were supplied immediately prior to the regulations taking effect) or to a designated person. On December 16, 2022, the Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022 went into effect.

"Strengthening the financial sanctions regime is a vital component of the government's reaction to war in Europe," said Paul Philip, Chief Executive of the SRA. The sanctions regime applies to all legal service providers, not simply those covered by anti-money laundering rules. Because this is a complex and fast-moving scenario, we issued preliminary guidelines last month. Firms would benefit from signing up for OFSI notifications to be informed, as well as doing adequate checks on clients and potential clients."

The term "trust services" is defined in the amendment as follows:

the establishment of a trust or other comparable structure

the providing of a trust or similar structure with a registered office, business address, correspondence address, or administrative address

the operation or management of a trust or similar arrangement acting or arranging for another person to act as trustee of a trust or similar arrangement, where "trustee" refers to a person who holds an equivalent or similar position to a trustee of a trust in relation to an arrangement similar to a trust.

The definition of "associated with Russia" is stated in rule 19(A)2. A person is regarded to be related with Russia if they regularly dwell or are located in Russia. A person other than an individual is linked to Russia if it is incorporated/formed under Russian law or is based in Russia.