Sanctions screening for solicitors: from matter opening to completion

Sanctions review is a matter-management task

A law firm needs more than a search at the start of a relationship. The people, entities and payment instructions on a matter can change between opening a file and completing the work. A practical procedure makes those changes visible to the person responsible for the next decision.

The SRA’s sanctions guidance applies to all SRA-regulated firms, not only work within the Money Laundering Regulations. It addresses screening, ownership and control, licensing and reporting. Sanctions compliance is distinct from the SRA’s disciplinary sanctions regime.^[1]

Do not infer an exemption from the size of your practice, the absence of a client account or a client’s local address. Instead, establish a matter-specific review scope. The suggestions below are operational controls for a firm to assess and adapt; they are not a statement that every suggested search is a separate statutory requirement.

Identify the parties and their roles

Start with the client and the legal entity involved, then work outward from the matter. For a conveyance, write down the buyer, seller and any relevant corporate ownership or third-party funding questions. For corporate work, distinguish the company receiving advice from the individuals giving instructions and the entities receiving assets.

Use roles, not an undifferentiated list of names. “Director”, “seller”, “beneficial owner” and “payer” tell a later reviewer why a person mattered. If a colleague adds someone after the original searches, the file should show whether that person has been assessed or remains outstanding.

The SRA recommends a firm-wide sanctions risk assessment and provides a template. It is good practice rather than a compulsory standalone document. Use it to decide where your firm needs more experienced reviewers, clearer information requirements or specialist advice.^[2]

• Define who owns sanctions review for the matter and who can resolve uncertainty.
• Record the client’s legal identity and relevant ownership or control information.
• Consider counterparties, funding parties and recipients in the context of the work.
• Make unresolved checks visible before staff can treat the matter as ready to proceed.

Put review points before the decisions they support

Our suggested conveyancing workflow has an initial review at matter opening, a review when material party or funding details change, and a check that outstanding sanctions questions are resolved before affected funds are dealt with. These are proposed control points, not a universal timetable imposed by legislation.

A completion checklist should refer to the underlying review record. “Search done” is too ambiguous: it could mean someone typed a name, a batch finished, or every potential match was actually considered. Use separate statuses for a completed search and a completed review.

Illustrative example: an invented corporate buyer changes the proposed source of its deposit shortly before completion. The earlier client search remains part of the evidence, but it does not answer the new funding question. The fee earner flags the change to the nominated reviewer instead of copying the old clearance date onto the revised instructions.

Make the screening evidence reproducible

The UK moved to the UK Sanctions List as its sole designations source on 28 January 2026. Procedures referring staff to the retired OFSI Consolidated List need updating.^[3]

Save enough context to reproduce the reasoning: the entered name, the available identifiers, the source record and the date of review. Where a result is rejected as a different person, identify the evidence that supports that conclusion. Where information is missing, retain the question and the person responsible for obtaining an answer.

Do not add a similarity score to a file as though it were a legal opinion. Nor should “no results” silently become “no sanctions exposure”. Keep the coverage limits, any unavailable sources and separate ownership or service-restriction analysis visible. The strongest file explains what was established and what was outside the check.

Treat client money and licensing as separate decisions

Where restrictions apply, accepting fees, handling money or carrying out work may require a licence or an applicable exception. The SRA explains that different licensing bodies cover different sanctions and that overlapping restrictions can require more than one authorisation.^[1]

For an unresolved concern, pause the affected action and obtain an assessment from someone with the appropriate expertise. Avoid improvising by returning, redirecting or moving funds to another account. Record which action is paused, which legal question needs answering and who is authorised to make the decision.

If relying on a licence, maintain a record of its scope and conditions rather than only its reference number. A useful internal handover identifies the authorised activity, relevant parties, any limits and the person tracking required follow-up. Do not assume that submitting an application is permission to proceed.

Build an escalation route that accounts for privilege

The SRA explains that reporting duties do not override legal professional privilege, but a blanket refusal to share information on that basis may be challenged. Record the reasoning and sign-off when privilege affects a report; seek advice where needed.^[1]

Your internal process should distinguish an operational alert, a legal assessment and any external report. Restrict access to sensitive advice and avoid copying an entire matter file into a screening note. The reviewer needs the evidence relevant to their decision, with a controlled link to further material where appropriate.

For supervision, sample a few closed reviews and ask a colleague to reconstruct the decision without speaking to the original fee earner. If they cannot understand why a result was dismissed, improve the record template. That simple test is often more useful than measuring how many green ticks appear in a dashboard.

• Record the issue, affected activity and responsible decision-maker.
• Assess reporting, regulatory notifications, licensing and privilege through the appropriate route.
• Retain the decision and its rationale, not only the screening output.
• Revisit the matter when relevant parties, instructions or source information change.