Context
The UK Sanctions List has been the primary list of sanctions designations made under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA) since launching in 2020. It provides a comprehensive list of those persons placed under sanctions. The sanctions restrictions can include financial, immigration, trade or transport sanctions. This differs from the OFSI Consolidated List which provides information on those subject to UK financial sanctions only.
Key points to note and next actions
The Cross-government review of sanctions implementation and enforcement announced earlier this year that the UK will be moving to having a single list for all UK sanctions designations. This is in response to industry feedback that a single list will remove duplication of effort and simplify checks of who is subject to UK sanctions.
From Wednesday 28 January 2026, the UK Sanctions List (UKSL) will be the only sanctions list which details sanctions designations published by the UK government. The OFSI Consolidated List and its search tool will no longer be updated from this date.
Firms will need to ensure that by Wednesday 28 January 2026, any systems that use the OFSI Consolidated List for sanctions screening purposes are instead using the data from the UK Sanctions List. Any systems that use ‘OFSI Group ID’ as an identifier will need to use the UK Sanctions List’s ‘Unique ID’ for new Designated Persons (DPs).
All UK Sanctions List formats will retain historic OFSI Group ID identifiers for DPs designated prior to 28 January 2026. These historic Group IDs will remain valid for use, for example in licence applications, frozen asset or suspected breach reporting, though UKSL Unique IDs can also be used.
Firms should not wait to begin this process and can make adaptations immediately. If you use a specialist screener or other third-party providers, you should speak to your supplier to understand the impact, if any, on data you receive. Firms should use this period before January 2026 to prepare any systems for the formal closure of the OFSI Consolidated List.
It is recommended that firms switch to the UK Sanctions List as its primary source of designations data now, and in any case no later than 28 January 2026.
H M government will not be publishing a draft template of the UK Sanctions List. This is because the UK Sanctions List is currently live and can already be used for screening and to compare any differences between the structure of the 2 lists. Structural changes will not be made to the published UK Sanctions List formats as part of this work. Which format of the UK Sanctions List you use is a decision for you and your organisation.