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Question 1

Do you know how RICS has responded to the current war ongoing in Ukraine?

Answer 1

• RICS has produced a note to ensure that firms complying with the UKs sanctions that they have imposed on Russia in response to their unjust invasion of Ukraine.
• The note reaffirms that under the RICS rules of conduct, members and firms must not facilitate any financial crime including money laundering, tax evasion, bribery or corruption.
• Also reaffirms that in accordance with the RICS professional statement - Countering bribery and corruption, money laundering and terrorist financing, all RICS-regulated firms must have a written policy for addressing money laundering and terrorist risk financing risks that covers the identification of politically exposed persons, persons with significant control and potential breaches of sanctions.
• The note provides practical tips to help firms comply which include:

1. Carefully consider the risks to your business as part of you anti money laundering procedure. You cannot just categories clients that need checking just on their nationality.
2. You may need to check clients or transactions with links to jurisdictions subject to the sanctions, even if the client is local. There maybe complex cooperate structures in place or clients that seem unable to receive or send funds from accounts in their own name.
3. If you are at high risk dealing with clients on the sanctions list you may want to use specialist software to carry out checks.