Until the Getting Started Wizard is live, use this guide to identify the information your firm needs to provide. When an option is presented, copy the option that applies and paste it into the policy, replacing the bracketed placeholder.
At a glance
Total customisation points: 7
Personalised fields (firm-specific text to insert): 6
Applicability toggles (choose which option applies): 1
Section: About this policy / 3.1 Governance
[Sanctions Nominated Officer] — Personalised Field
Question: Who is the firm's Sanctions Nominated Officer?
Guidance: Insert the name of the firm's Sanctions Nominated Officer. This person oversees the firm's sanctions compliance framework, makes decisions about work involving designated persons, and authorises licence applications to OFSI or OTSI.
[COLP] — Personalised Field (cross-policy)
Question: Who is the firm's Compliance Officer for Legal Practice (COLP)?
Guidance: Insert the name of the firm's COLP. The COLP has ultimate responsibility for all aspects of compliance within the firm.
Section 2 — Policy statement
[firm name] — Personalised Field (cross-policy)
Question: What is the firm's name?
Guidance: Insert the full legal name of the firm as registered with the SRA.
Section 3.3 — Screening process
[screening system] — Personalised Field
Question: What sanctions screening system does the firm use?
Guidance: Insert the name of the firm's primary sanctions screening tool. If the primary system is unavailable, staff must conduct manual checks against the UK Sanctions List.
Section 3.1 — Governance
[sanctions committee section] — Applicability Toggle
Question: Has the firm established a sanctions committee?
Guidance: Select whether the firm has a dedicated sanctions committee to support the Sanctions Nominated Officer, and follow instructions where prompted.
Options:
Option A (No): The firm has not established a separate sanctions committee. The Sanctions Nominated Officer has sole responsibility for sanctions compliance decisions, supported by the COLP and senior management.
Option B (Yes): The firm has established a Sanctions Committee comprising INSERT COMMITTEE MEMBERS. The committee meets INSERT FREQUENCY to review sanctions risks, screening outcomes, and policy effectiveness.
Section 4.7 — Independent sanctions audit
[sanctions audit frequency] — Personalised Field
Question: How frequently does the firm conduct independent sanctions audits?
Guidance: Insert the frequency of independent audits of the firm's sanctions compliance regime (e.g. annual, bi-annual).
[sanctions audit method] — Personalised Field
Question: How are independent sanctions audits carried out?
Guidance: Insert how the firm's independent sanctions audits are conducted. Examples: by an external compliance consultant, by a designated internal auditor independent of the sanctions function, by a panel of senior partners.