A sanctions regime prohibits Russia from receiving trust services.

The Office of Financial Sanctions Implementation operates the United Kingdom's system (OFSI). The government imposes certain restrictions in order to achieve particular foreign policy or national security objectives.

The regime, which is supported by multiple pieces of legislation, has undergone numerous revisions in recent years. The Solicitors Regulation Authority (SRA) has already produced recommendations for businesses to ensure that they comprehend their obligations.

The government has recently enacted changes prohibiting the provision of trust services to individuals with ties to Russia (unless the services were supplied immediately prior to the regulations taking effect) or to a designated person. The Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations of 2022 took effect on December 16, 2022.

Paul Philip, chief executive officer of the Solicitors Regulation Authority (SRA), stated, "Strengthening the financial sanctions framework is a crucial component of the government's response to the war in Europe, and legal firms play a crucial role. The sanctions regime applies to all firms providing legal services, not simply those covered by the anti-money laundering rules. This is a dynamic and complex situation, which is why we published our initial advise last month. Firms would be well-advised to sign up for OFSI notifications in order to stay informed, as well as to conduct appropriate client and potential client checks."

The modification defines "trust services" as:

the formation of a trust or a comparable arrangement.

the providing of a registered office, business address, correspondence address, or administrative location for a trust or comparable entity

the operation or management of a trust or similar arrangement; acting or arranging for another person to function 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 accordance with regulation 19(A), a person is considered to be "associated with Russia." In general, a person is deemed to have ties to Russia if he or she resides or is physically present in the country. A person other than an individual has ties to Russia if it is incorporated or formed under Russian law or has its domicile in Russia.