The sanctions system prohibits trust services for Russia.

Office of Financial Sanctions Implementation administers the British system (OFSI). The government imposes these measures to achieve certain foreign policy or national security goals.

Recent years have witnessed a lot of modifications to the regime, which is supported by various pieces of law. The Solicitors Regulation Authority (SRA) has already produced recommendations to help businesses understand their responsibilities.

The government has enacted amendments 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. On 16 December 2022, the Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations entered into force.

Paul Philip, chief executive officer of the SRA, stated, "Strengthening the financial sanctions framework is a crucial component of the government's response to the war in Europe, and law firms play a crucial role. The penalties regime applies to all law firms, not simply those caught by anti-money laundering legislation. This is a complex and rapidly-changing scenario, which is why we released our initial recommendations last month. Firms would do well to sign up for OFSI notifications in order to stay informed, and to conduct adequate checks on clients and potential clients.

The amendment specifies the following as "trust services":

the establishment of a trust or comparable arrangement

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

acting or arranging for another person to act as trustee of a trust or similar arrangement, where "trustee" in respect to an arrangement comparable to a trust indicates a person who has a position equivalent or similar to a trustee of a trust.

The regulation 19(A)2 defines who is considered to have a "connection with Russia." A person is generally considered to have ties to Russia if he or she resides or is located in Russia. A non-individual is connected to Russia if it is formed or organized under Russian law or has its domicile in Russia.

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