Is there a de minimis amount for sanctions?

We offer fixed fee consultations for litigation work and undertake electronic verification, including sanctions checks, before the appointment. Is there a de minimis amount for sanctions?

The sanctions regime is unlike the anti-money laundering (AML) regime in that it does not differentiate between ‘in scope’ and ‘out-of-scope’ work.

The Solicitors Regulation Authority (SRA) guidance on complying with the UK sanctions regime contains a useful summary of the differences between AML and sanctions.

There is no de minimis amount, so if your client is a designated person, you will need to:

  • put a freeze on any paid work
  • consider your reporting obligations to the Office for Financial Sanctions Implementation and any licence you may need

For more information, see the UK government guidance on what to do if you suspect a breach of financial sanctions.


While every effort has been made to ensure the accuracy of the information in this article, it does not constitute legal advice and cannot be relied upon as such. The Law Society does not accept any responsibility for liabilities arising as a result of reliance upon the information given.

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