JURISDICTION SCREENING GUIDES · GUIDEUPDATED 2026-08-20
Jurisdiction Screening Guides
UK Sanctions Screening: UK Sanctions List and OFSI Workflow
How UK sanctions screening works — the UK Sanctions List, SAMLA and the regime regulations, the ownership and control test, OFSI and OTSI enforcement, and reporting duties for relevant firms.
UK sanctions screening checks people, entities and ships against the UK Sanctions List, the register of everyone designated under the Sanctions and Anti-Money Laundering Act 2018 and the regime-specific regulations made under it, such as the Russia (Sanctions) (EU Exit) Regulations 2019. The list is maintained and published by the Foreign, Commonwealth and Development Office, which also makes designations on behalf of the Secretary of State. Implementation and civil enforcement of financial sanctions sit with the Office of Financial Sanctions Implementation, part of HM Treasury; trade, aircraft and shipping sanctions are civilly enforced by the Office of Trade Sanctions Implementation within the Department for Business and Trade, launched in October 2024, while HM Revenue and Customs and the National Crime Agency handle criminal enforcement. The United Kingdom formerly published two overlapping registers — the FCDO's UK Sanctions List and OFSI's Consolidated List of Asset Freeze Targets — but the OFSI consolidated list was closed to updates in January 2026 and the UK Sanctions List is now the single authoritative source. UK financial sanctions bind all UK persons wherever they are in the world, and everyone within the United Kingdom and its territorial sea.
What this workflow covers
SCOPE- Screen the UK Sanctions List published by the Foreign, Commonwealth and Development Office — the single authoritative register of UK designations, available in HTML, PDF, ODS, CSV and XML.
- Do not rely on OFSI's former Consolidated List of Asset Freeze Targets, which closed to updates in January 2026 and remains online only for historical reference.
- Understand the legal structure: the Sanctions and Anti-Money Laundering Act 2018 is the framework statute, and each regime's prohibitions live in its own regulations made under that Act.
- Apply the UK ownership and control test — holding directly or indirectly more than 50 percent of the shares or voting rights, the right to appoint or remove a majority of the board, or the ability to ensure the entity's affairs are conducted in accordance with the designated person's wishes.
- Note that the UK Sanctions List covers more than asset freezes: it identifies designations for financial, immigration, trade and transport sanctions, including ship and aircraft specifications.
- Treat civil liability as strict — OFSI may impose a monetary penalty for a financial sanctions breach without needing to show that the firm knew or had reasonable cause to suspect it.
- Meet the reporting obligation: relevant firms must report to OFSI as soon as practicable where they know or reasonably suspect that a person is a designated person or has committed a breach, and must report frozen funds they hold.
- Apply for an OFSI licence where an exception does not cover the activity, and use OTSI's route for trade, aircraft and shipping sanctions questions.
- Screen the UK list separately from the EU list — the two have diverged since the United Kingdom's departure from the EU on designation timing, scope and individual names.
- Subscribe to the joint FCDO, OFSI and OTSI email alert service and re-screen on list change; UK designations are published frequently, often several times a week.
Key statistics
DATA- Authoritative register
- The UK Sanctions List (FCDO) — single source since January 2026
- UK Foreign, Commonwealth & Development Office
- Framework statute
- Sanctions and Anti-Money Laundering Act 2018 (SAMLA)
- UK Legislation
- Financial sanctions enforcement
- OFSI (HM Treasury) — strict liability civil monetary penalties
- HM Treasury
- Trade, aircraft and shipping enforcement
- OTSI (Department for Business and Trade), from October 2024
- UK Department for Business and Trade
Compliance glossary
TERMS- UK Sanctions List
- The register maintained by the Foreign, Commonwealth and Development Office of all persons, entities and ships designated under the Sanctions and Anti-Money Laundering Act 2018, recording which financial, immigration, trade or transport measures apply to each.
- OFSI
- The Office of Financial Sanctions Implementation, part of HM Treasury, responsible for implementing and civilly enforcing UK financial sanctions, issuing licences, and receiving reports of designated persons and frozen assets.
- SAMLA 2018
- The Sanctions and Anti-Money Laundering Act 2018, the framework statute giving UK ministers the power to make autonomous sanctions regulations and to designate persons under them following the United Kingdom's departure from the European Union.
- Relevant firm
- A category of business — including financial institutions and other regulated sectors — subject to a duty to report to OFSI knowledge or reasonable suspicion that a person is a designated person or has breached financial sanctions, and to report frozen funds held.
- Ownership and control test (UK)
- The statutory test for treating an entity as owned or controlled by a designated person: more than 50 percent of shares or voting rights held directly or indirectly, the right to appoint or remove a majority of the board, or the ability to ensure the entity's affairs are conducted in accordance with the person's wishes.
Authoritative references
SOURCES- 01The UK Sanctions List
UK Foreign, Commonwealth & Development Office
- 02
- 03Office of Trade Sanctions Implementation (OTSI)
UK Department for Business and Trade
- 04Sanctions and Anti-Money Laundering Act 2018
UK Legislation
Expert perspective
NOTE“Since Brexit, OFSI's UK sanctions list has diverged from the EU's on designation timing and scope — treating the two lists as interchangeable is a gap waiting to surface.”
Frequently asked questions
Q&A- What is the UK Sanctions List?
- The UK Sanctions List is the register published by the Foreign, Commonwealth and Development Office naming every person, entity and ship designated under the Sanctions and Anti-Money Laundering Act 2018 and its regime regulations. It records which sanctions apply to each designation — financial, immigration, trade or transport — together with identifying details and the statement of reasons.
- What happened to the OFSI Consolidated List?
- OFSI's Consolidated List of Asset Freeze Targets closed to updates in January 2026 and is no longer maintained, leaving the FCDO's UK Sanctions List as the single authoritative source for all UK designations. The change removed the duplication created by two overlapping registers. Screening systems still pointed at the old consolidated list will silently fall out of date.
- Who enforces UK sanctions?
- Responsibility is split. The Office of Financial Sanctions Implementation, part of HM Treasury, implements and civilly enforces financial sanctions and issues licences. The Office of Trade Sanctions Implementation, within the Department for Business and Trade, civilly enforces trade, aircraft and shipping sanctions. HM Revenue and Customs and the National Crime Agency handle criminal investigation and prosecution.
- Who must comply with UK financial sanctions?
- All UK persons — British nationals and bodies incorporated or constituted under the law of any part of the United Kingdom — wherever in the world they are, and every person within the territory of the United Kingdom, including its territorial sea. A UK company's overseas branch is therefore in scope, and a foreign firm operating in the United Kingdom is in scope for its UK conduct.
- What is the UK ownership and control test?
- An entity is treated as owned or controlled by a designated person where that person holds directly or indirectly more than 50 percent of the shares or voting rights, holds the right to appoint or remove a majority of the board, or where it is reasonable to expect the person can ensure the entity's affairs are conducted in accordance with their wishes. Any limb can be enough.
- How often is the UK Sanctions List updated?
- Frequently and without a fixed schedule — often several times a week across the active regimes. Designations take effect when made, so screening should refresh on list change rather than on a calendar. The FCDO, OFSI and OTSI operate a joint email alert service that notifies subscribers when designations and guidance change.
- Is the UK sanctions list the same as the EU list?
- No. Since the United Kingdom left the European Union it operates an autonomous regime under its own legislation, and although the two lists overlap heavily they diverge on designation timing, scope and particular names. Using one as a proxy for the other leaves gaps in both directions, so organisations with exposure to both should screen both.
- Do UK firms have to report suspected sanctions breaches?
- Relevant firms — including financial institutions and a range of other regulated businesses — must inform OFSI as soon as practicable where they know or have reasonable cause to suspect that a person is a designated person or has breached financial sanctions, where that information came to them in the course of business. They must also report funds or economic resources they hold and freeze.
- Can OFSI fine a firm that did not know it was breaching sanctions?
- Yes. OFSI's power to impose civil monetary penalties operates on a strict liability basis: it does not have to establish that the firm knew or had reasonable cause to suspect the breach. Knowledge and the quality of the firm's compliance controls remain relevant to the size of any penalty and to whether the case is referred for criminal investigation.
- What is OTSI and how is it different from OFSI?
- The Office of Trade Sanctions Implementation, launched within the Department for Business and Trade in October 2024, civilly enforces trade, aircraft and shipping sanctions and can impose monetary penalties and require information. OFSI, by contrast, sits in HM Treasury and covers financial sanctions — asset freezes, licensing and financial-sector reporting. Many businesses have obligations to both.
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