A 45-minute, CPD-assessed course for everyone who could touch a payment, an account or a client instruction. Sanctions are prohibitions, not risk ratings: the transaction stops first and is investigated afterwards. Rewritten for 2026, and scheduled, chased and certified for you.
It is tempting to treat sanctions as a kind of due diligence. That builds the AML reflex, investigate and then report, which is exactly wrong here.
The money stops moving that day, whether or not anybody has finished investigating. A sanctions match is a prohibition, not a risk rating.
Internally, the same day. Not after a fortnight of looking into it, and not by deciding first whether the concern is well founded.
A financial sanctions breach goes to OFSI and a trade sanctions breach to OTSI. Neither is a suspicious activity report to the NCA.
Written for a financial services firm, where the risk is a counterparty nobody listed, an alert nobody closed and a supplier nobody screened.
The kinds of restriction, who is who (the FCDO, OFSI, OTSI and the FCA), who the rules bind, and why helping around them, circumvention, is an offence of its own.
The risk that catches firms out most, how evasion actually looks, and where it turns up in a financial services firm. Includes a filmed scenario.
What screening is good at and what it is not, ownership and control as the gap screening cannot close, and what to do when an alert fires.
Freeze, escalate internally, report externally: who gets told and why it is not a SAR, why speed is measured, what you must not say to the customer, what happens when a designation lands on somebody the firm already acts for, and what to do if the client says it is a mistake.
Why a country regime is not a country ban, trade sanctions and why they are a financial firm's problem, OTSI and the reporting duty a regulated firm may not know it has, intermediaries, and why it is not only clients who need screening.
What good training looks like, who is answerable, two habits the FCA called out, and what the firm has to be able to show.
What to take away, followed by the test and the certificate.
Penalty amounts and thresholds all moved during 2026, so the course teaches the behaviour that does not move. By the end, a learner can:
A short film, shot for Fundsure with the same cast across the catalogue, puts the learner beside a colleague with a sanctions concern about a client’s arrangement and a transaction about to go. The learner chooses what she should do, and is told why the tempting answers are wrong: asking the client to explain, processing it with a note on the file, or letting it through and raising it with the MLRO later.
The test at the end draws 10 questions from a bank of 30, with a pass mark of 80%, and a pass issues a named, CPD-marked certificate that anyone can check online.
Checked against government, OFSI, OTSI and FCA publications. Last checked Sept 2026.
The UK Sanctions List is now the only source for UK designations. OFSI's consolidated list closed and is no longer updated, so a screening feed still pointed at it is screening against a frozen snapshot.
Rewritten 09-Feb-26: fixed penalties for reporting and licensing failures, a seriousness matrix, and settlement and early account schemes. Reporting failures are now penalised in their own right.
Published 28-May-26 after looking at over 150 firms: screening weaker on name variants than exact matches, alerts closed slowly, trade sanctions the least developed area, and over-reliance on group and vendor arrangements.
The most common way a UK firm breaches financial sanctions: the counterparty is on no list, the person behind it is. More than one 2026 penalty turned on exactly this.
OTSI penalises on a strict liability basis, and regulated financial services firms have their own legal duty to report a third party they suspect of breaching trade sanctions.
The offence most likely to reach ordinary staff looks administrative: rerouting, restructuring, rewording an invoice. And what to do when a designation lands on somebody the firm already acts for.
OFSI can penalise a firm for a financial sanctions breach without proving it knew anything, and OTSI penalises trade sanctions breaches on the same strict basis. A criminal conviction still needs knowledge or reasonable cause to suspect, which is why what each person does with an alert matters so much.
The FCA expects firms to be able to show their staff are trained. In the Fundsure Portal every sitting, score and certificate is kept and carried into the compliance officer’s report to the board.
How the portal runs trainingSanctions Awareness plus AML and CTF, anti-bribery, anti-tax evasion, Conduct Rules and the rest of the catalogue of 20, with no per-course fees.
Money laundering and terrorist financing: a different regime with different people to tell.
See the courseAgents, gifts and hospitality, facilitation payments and raising a concern.
See the courseThe corporate offence of failing to prevent the facilitation of tax evasion.
See the courseFor trust and company service providers under HMRC supervision.
See the courseWe will send you a link to take the whole course, filmed scenario and test included, or walk you through the portal with a demonstration firm.
