One List to Rule Them All:

UK Sanctions List to Reign Supreme

Starting next week, on January 28, 2026, the UK will transition from maintaining two lists of sanctions designations to one. Specifically, as part of the UK’s efforts to simplify its sanctions regime, the UK Sanctions List will become the authoritative list for any companies required to screen their clients and third parties in order to comply with UK sanctions laws.

Thanks to Brexit, the UK has had to develop its own sanctions regime over the last several years, and ultimately settled on two overlapping but different sanctions target lists: the UK Sanctions List and the Consolidated List of Asset Freezes (the “Consolidated List”). These lists serve different purposes and are maintained by different government bodies.

The UK Sanctions List is administered by the Foreign, Commonwealth, and Development Office and consists of a comprehensive list of all UK sanctions targets (i.e., entities and people subject to immigration, financial, trade, and transport sanctions). The Consolidated List, on the other hand, lists entities and people that are subject only to UK financial sanctions, and is published by the Office of Financial Sanctions Implementation (“OFSI”).

The move to using a single sanctions list was initiated when the UK’s Minister for Europe launched a review of sanctions enforcement across the UK’s various governmental bodies, with the aim of finding ways to strengthen sanctions enforcement. Six months after this review started, the Foreign, Commonwealth and Development Office published a policy paper recommending consolidating the two sanctions lists into a single list that contains all UK designations.

What to do next?

If your firm is required to comply with UK sanctions, a few actions that would facilitate compliance with this latest update include:

• Ensuring that any screening tools, vetting solutions, and other systems only screen against the UK Sanctions List going forward.
• Reviewing the format of the UK Sanctions List and the relevant URLs to ensure your systems are using the most up to date formats and links.
• Ensuring the relevant professionals within your organization are aware of the change and know which steps to take to comply with it. Specifically, staff should understand where to find the UK Sanctions List, how to use the list’s search features, which identifiers to include in internal reports, and why sanctions designations will not include OFSI Group IDs going
  forward.
• Updating internal policies, procedures, and risk assessments to reflect the fact that the UK Sanctions List is the authoritative list against which to screen going forward.
• Reviewing contracts to update references to the relevant lists where appropriate.
• Connecting with any vendors or third parties that assist with sanctions screening to ensure they are making the necessary updates as well.

UK regulators will expect firms to be able to demonstrate how they prepared for this list update. Firms should build a record of impact assessments, end-to-end testing, internal controls updates, steps taken with their outside vendors, and contract updates. Sanctions compliance is a dynamic field, with constantly changing regulations and increasing regulatory expectations. Some sanctions changes are prompted by geopolitical events (e.g., Russia’s invasion of Ukraine), while others are motivated by a desire to simplify, consolidate, and streamline how companies can screen for sanctioned parties. Either way, sanctions screening lists should be periodically tested and reviewed to ensure continued compliance.