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AML Update Service extract for :
Russian sanctions circumvention
Change Date : 12/10/2026 | Word Count: 167 | Deployment Measure : 8/10
Rationale:
Covers the OFSI/OTSI guidance on third-country routing, dual-use goods, and layered ownership structures, with a clear escalation obligation to the MLRO.The SRA's August 2026 Sectoral Risk Assessment specifically identifies Russian sanctions circumvention as an emerging risk for legal services providers. Since the invasion of Ukraine, a range of techniques have
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