This should assist firms as they deal with the written risk assessment of their practice and the risk assessment of individual clients.

HMRC have also provided information relating to Understanding risks and taking action for Trust or Company Service Providers and members undertaking work of this nature may also find it helpful to refer to this document.

Proliferation Financing (PF) Risk Assessment

Since 1 September 2022 all regulated entities have been required to have a Proliferation Financing Risk Assessment. 

For further details of relevant risks refer to

The Financial Action Task Force guidance 

The UK Proliferation Financing National Risk Assessment 

The only UN sanctioned countries at present are Iran and North Korea. The UK has also implemented an autonomous sanctions regime on chemical weapons and individuals and entities from Syria and Russia have been designated under this regime.

On this basis we expect there to be limited risk exposure for firms supervised by the ATT.  When next updating the pro forma documents we will include wording in relation to PF risk assessment for a firm but in the meantime, we suggest that firms include the wording below in their practice risk assessment where:

• there are no client links to Iran or North Korea; and

• where sanction checks have been undertaken for clients linked to Russia and Syria and no chemical weapons sanctions have been identified.

Risk assessment wording:

Our client base has been reviewed for proliferation financing risks and we are satisfied that neither our clients nor the firm are at risk of breaching the associated sanctions. Our overall proliferation financing risk is therefore low.

 

Page last updated 22 May 2023