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Sanctions, sanctions, sanctions…what the education sector needs to know

Sanctions are in the news due to the ongoing conflict in Ukraine.  Sanctions have an impact on businesses and organisations throughout the UK, including those operating in the education sector.

 Sanctions are commercial and financial penalties imposed by one country against another or on particular entities and individuals, with the aim of trying to stop certain acts or behaviours.  Whilst sanctions are imposed at government level, businesses and organisations are required to ensure that they are aware of current sanctions which are in place and that they act in accordance with them.

To ensure that they act in accordance with current sanctions imposed by the UK government,  schools should be undertaking due diligence to check whether any of their student’s places are being funded by sources that are on the UK sanctions list and by carrying out the usual background checks to ensure they know who they are contracting with and the source of funds.  In addition, before accepting any third-party donations, the identity of the third party and the proposed source of funds must be checked to ensure that accepting the proposed donation will not be contrary to a current sanction.

The sanctions list is updated regularly and includes individuals and other entities (including banks).  The most up to date list can be found here.

In essence, schools must not accept any payments from any sources which are subject to sanctions.  Breaching a sanction could result in criminal prosecution or a fine being imposed.

It should also be noted that the current sanction list extends beyond Russia and its oligarchs.  It is also continually being updated.

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