Key takeaways

• From 8 August 2017, professional advisers operating in the UK, such as accountants, lawyers and auditors, are under an obligation to report any known or suspected breaches of EU financial sanctions to the UK’s Office of Financial Sanctions Implementation (“OFSI”).
• This new reporting obligation expands the existing reporting obligation on UK financial institutions and expands the general EU obligation for persons to provide information to EU authorities to “facilitate compliance” with EU sanctions.
• Transactions involving UK professional advisers which raise suspicions of sanctions breaches are therefore now more likely to come to OFSI’s attention and to face potential enforcement action.