The crisis in Ukraine and the importance of sanctions compliance

"RICS is deeply concerned by the attack on Ukraine and the terrible consequences for the Ukrainian people. Our thoughts are with them at this time, and we hope that there is an end to the invasion soon.

We strongly support all the steps being taken by the international community against the Russian state, institutions and individuals and are supporting our members to implement the sanctions imposed. We are also offering any support we can to our members in Ukraine, and Lionheart is providing financial and emotional support to those members and their families.

We have very carefully considered whether we should take action against members and firms based in Russia. We are not currently accepting any payments from or providing any services to those members and firms. However, our rules do not allow us to suspend or remove members or firms without evidence of wrongdoing by the individual or firm, and we believe it would be unethical to do so. We know that many Russians do not support the actions of their government.

We would of course take action against any member or firm who is failing to comply with sanctions or who is helping others to evade them. Our members and firms have an obligation under our Rules of Conduct to speak up and report such misconduct if they suspect it."

- Richard Collins, Interim CEO

In light of the sanctions being imposed by governments in response to these events, we would remind our members and firms of the important role they play in ensuring that sanctions are complied with.

The requirements in the global professional statement “Countering bribery, corruption, money laundering and terrorist financing” include the need to check if a potential customer or client (or their ultimate beneficial owner) is under any relevant sanctions that would prohibit you from establishing a business relationship with them.

Given the developing crisis firms should review their anti-money laundering policies in light of the increased risks. In particular we would strongly suggest that firms and members adopt an extremely careful approach to due diligence checks.

Members and firms must check the sanctions list for their jurisdiction – for example see the UK sanctions list – before offering services or undertaking transactions for clients. Where concerns arise firms should follow any requirements in their jurisdiction for reporting suspicious activity.

Complying with sanctions is both a legal and ethical obligation, and there can be serious consequences for failures to do so.

RICS firms and members must also comply with the Rules of Conduct including Rule 1 requiring them to act with integrity and Rule 5 requiring them to act in the public interest and maintain public confidence in the profession. Members and firms should consider the risk to their reputation, the reputation of the profession and the public interest in deciding whether to accept instructions from specific clients.

Latest update 7th April 2022

Many charities (including Lionheart) are providing support to Ukrainian refugees and have launched emergency appeals for donations. Supporting these is a practical step that many of us have already taken where we can and will continue to take. RICS is also using its network to support Ukrainian members of RICS who are looking for work. At the moment we are handling requests for help in finding work in the Netherlands, Germany and Bulgaria. If any members or firms can support with providing opportunities for work please contact our AEMEA membership support team who are coordinating these efforts (aemea@rics.org).

We know that some members have been asking whether there are practical steps they can take, when the time comes, to support reconstruction work in Ukraine. Members might want to donate and support NGOs that provide support to countries and the UN in undertaking this work for example:

• Humanitarian training and support for NGOs and aid workers worldwide - RedR
• MapAction – The humanitarian mapping charity

RICS will also use its contacts within UN agencies and the EU to offer help and link members with appropriate expertise and post conflict/disaster training to relevant bodies when that expertise is needed in Ukraine. However it is important that this work is led by Ukraine itself, the surveyors in that country and appropriate international agencies which RICS will support wherever it can.

Ukraine Crisis – Q&A Guidance