The UK Sanctions List: What It Covers and What It Leaves Out

What is the UK Sanctions List?

The UK Sanctions List names the individuals, entities and ships that are the targets of UK sanctions measures. It has been published since 2020 and records designations and specifications made under sanctions regulations created under the Sanctions and Anti-Money Laundering Act 2018, usually shortened to SAMLA. The Act gave the United Kingdom its own sanctions framework after it left the European Union. Each list entry records who the target is, which sanctions regime it falls under and which measures apply, from asset freezes and travel bans through to arms embargoes, transport restrictions and director disqualification.

Under SAMLA, persons can be designated by name under section 11, while ships can be specified separately under section 14. The Act also allows an appropriate Minister, under section 12, to designate persons by description rather than individually by name. This means that the list records named designations and specified ships, but a person can also fall within a designation without their individual name appearing on the list.

What happened to the OFSI Consolidated List and the HM Treasury sanctions list?

The Office of Financial Sanctions Implementation (OFSI) closed its Consolidated List of Asset Freeze Targets at 9am UK time on 28 January 2026. Since that morning the UK Sanctions List has been the single published source for all current UK designations. Until then, the United Kingdom effectively maintained two overlapping lists, with the UK Sanctions List covered persons and ships designated or specified under sanctions regulations made under SAMLA, while OFSI separately maintained the Consolidated List only for financial sanctions.

Older guidance and compliance material may also refer to the HM Treasury sanctions list, often shortened to the HMT list. This was another name commonly used for the financial sanctions list maintained by OFSI, which is part of HM Treasury. Those targets now appear on the UK Sanctions List. The old OFSI Consolidated List and its search tool remain online as a historical record. They are no longer a current screening source. Designations made after 28 January 2026 do not appear in them.

One detail inside the data catches systems out, because the UK Sanctions list carries two identifiers. The Unique ID is the UK Sanctions List reference and every entry has one. The OFSI Group ID is the identifier that targets carried on the old OFSI Consolidated List. The format guide is explicit that it exists only for entries subject to financial sanctions before 28 January 2026. The FCDO's guidance note adds that historic Group IDs stay in every published format and remain valid for use, for example in licence applications and in frozen asset or suspected breach reporting, though UK Sanctions List Unique IDs can be used instead.

The risk is not that Group IDs stop working but that they no longer cover new designations. In the CSV published by the FCDO on 21 September 2026, 634 Unique IDs carry a designation date on or after 28 January 2026 and not one of them carries a Group ID, as counted by dilisense. A screening system that relies on Group ID to identify or link UK sanctions records could therefore process older entries while failing to capture newer ones. The same gap can arise where compliance policies or procedures still treat the OFSI Consolidated List as their reference source.

What is not on the UK Sanctions List?

Several important UK restrictions and exposures sit outside the names recorded on the UK Sanctions List. These include the financial and investment restrictions applying to persons named in Schedule 2 to the Russia (Sanctions) (EU Exit) Regulations 2019 (Russia Regulations), proscription under the Terrorism Act 2000, the asset freeze as it extends to entities owned or controlled by a designated person and designations made by description rather than by name. The list covers designations and specifications, not every UK sanctions exposure.

Eleven entities are named in Schedule 2 to the Russia Regulations and are subject to specific financial and investment restrictions, including restrictions under regulations 16 and 17 on transferable securities, money-market instruments, loans and credit. Those restrictions reach beyond the eleven names. They also cover entities that a named party owns, whether incorporated outside the United Kingdom or under the law of any part of it, and persons acting on behalf of or at the direction of either. "Owned" has a narrower meaning here than the general ownership and control test in regulation 7. Regulation 16(7) defines it as holding, directly or indirectly, more than 50 percent of the shares or more than 50 percent of the voting rights. Unlike regulation 7, it does not include the right to appoint or remove a majority of the board or the broader control test based on whether a person can ensure that an entity's affairs are conducted in accordance with their wishes. Schedule 2 therefore needs to be checked separately where these financial and investment restrictions are relevant; the UK Sanctions List alone does not capture them.

There are other reasons why checking the UK Sanctions List alone may not identify every relevant restriction. Organisations proscribed under the Terrorism Act 2000 are recorded separately by the Home Office. Proscription is a separate legal regime from sanctions designation, and not every proscribed organisation is also subject to financial sanctions. Entities owned or controlled by a designated person can be caught by the asset freeze without being designated in their own right, so their names are often absent from the list. Designations by description, as above, name a category rather than a person.

Ownership and control require a separate check because an entity can be subject to an asset freeze without being named on the UK Sanctions List. Under regulation 7 of the Russia Regulations, which sets the ownership and control test for that regime and is mirrored in comparable terms elsewhere, an entity is owned or controlled directly or indirectly by a designated person if either of two conditions is met. The first is met where the designated person holds, directly or indirectly, more than 50 percent of the shares or more than 50 percent of the voting rights in the entity, or holds the right to appoint or remove a majority of its board of directors. The second is met where it is reasonable, having regard to all the circumstances, to expect that the designated person would, if they chose to, be able, in most cases or in significant respects, by whatever means and whether directly or indirectly, to achieve the result that the affairs of the entity are conducted in accordance with their wishes. Either condition on its own is enough, so an entity can be caught by the asset freeze whether or not it appears on the UK Sanctions List. OFSI and the FCDO have published joint guidance on how the control limb applies, including to public officials.

How do you read an entry on the UK Sanctions List?

A designation entry carries far more than a name. The fields that matter most for matching are the name fields, the identifiers and the measures. Where any of the three is handled incorrectly in your own data model, a published designation can go undetected.

Names are split across six columns, in an order that does not follow the usual forename-to-surname sequence. Name 6 holds the surname of an individual or the full name of an entity or ship, while Name 1 to Name 5 hold forenames and middle names. Each record carries a name type, which is either the primary name, a spelling variation of it or an alias that is substantively different. Alias strength is generally recorded only for United Nations listings where the UN supplied it. Non-Latin script names are held in their own fields alongside information identifying the script or language, so a Persian or Arabic form sits alongside the transliteration rather than replacing it.

Identifiers on the list are frequently incomplete. The format guide states explicitly that a date of birth can be partially known and gives dd/mm/1970 as its example, a year with the day and month unknown. In the published data that is what the field carries, with the literal text dd and mm standing in for the missing parts, alongside bare years and the occasional malformed value. Passport and national identifier numbers appear where known, together with free text such as an expiry date. For ships the International Maritime Organization number (IMO) is the stable identifier, because it stays with the hull even when the name, owner or flag changes. The hull identification number is published as a column but carries no value for any ship entry.

The measures themselves are held in a Sanctions Imposed field with a fixed vocabulary, from asset freeze and travel ban to prohibition of port entry. The format guide warns that some measures have no indicator of their own and are published as an alternative sanction that can appear differently in the XML, naming transport sanctions, internet services sanctions, shipping sanctions and the prohibition on correspondent banking and sterling clearing among them. A system built only on the indicator fields could miss those measures. A measure that is not parsed can leave a prohibition unaddressed.

What formats can you download the UK Sanctions List in?

The UK Sanctions List is published in seven formats, namely ODT, ODS, XML, HTML, TXT, CSV and PDF, all carrying identical data and differing only in presentation, with no JSON among them as at September 2026. Since the January 2026 consolidation the URL for each format is static, so a link does not change when the list is refreshed. An XML schema is published alongside it.

The figures below come from dilisense's analysis of the CSV version of the file published on 21 September 2026. The CSV and TXT versions run to roughly 50 megabytes each and the XML to 22, large enough that most systems load the file on a schedule rather than fetching it on every check. That file carried 6,339 distinct Unique IDs across 31 regimes, breaking down into 4,032 individuals, 1,644 entities and 663 ships, with Russia by far the largest regime at 3,468.

The count is of Unique IDs rather than of natural persons, because aliases each take a row and a target designated under more than one regime can hold more than one Unique ID. Counting methods differ in whether they consolidate a target across regimes, how they subdivide the entity category and whether they index linked but undesignated parties, so a count of unique IDs is not directly comparable with every published figure.

OFSI's general guidance records that the FCDO aims to update the list within one working day for all new UN and UK listings coming into force in the UK and within three working days for all other amendments.

How do you search the UK Sanctions List?

You search the UK Sanctions List through the FCDO's free online search tool, one name at a time. The government's own user guide sets out its limits. Those limits are why it is not a substitute for a screening system.

The user guide documents no application programming interface, or API, and no bulk upload, so names go in one at a time rather than as a customer book. It also states that fuzzy matching is off by default. When switched on it allows one character of difference on a search term of three or four characters and up to two characters on anything longer. That can help with small spelling differences and some transliteration variants, but it will not capture every possible variation.

The user guide states that use of the tool "does not limit any criminal or civil liability or reduce the obligation to undertake due diligence". The tool reports what is on the list at the time of the search and the obligation to carry out customer due diligence stays with the organisation.

How do you screen against the UK Sanctions List?

Point your data source at the UK Sanctions List itself and retire any feed that still pulls the OFSI Consolidated List or an HM Treasury list under its old name. Then check how your system links records. If your system keys on the OFSI Group ID anywhere, designations made since January 2026 may not be picked up. That kind of gap typically produces no error.

Screen the separate Russia financial and investment restrictions list alongside the main file, because the Schedule 2 restrictions are not reflected in the UK Sanctions List entries. Handle the name fields as they are published, with Name 6 as the surname and the non-Latin forms kept rather than flattened. Allow for partial dates of birth instead of treating them as missing. Match ships on the IMO number rather than on the name or the flag, both of which can change.

Set your re-screening cadence by a risk-based approach, matched to the list rather than to your reporting calendar. The FCDO aims to publish new listings within one working day, so a refresh interval measured in weeks can leave a designated party in your book after designation. Keep your case records continuous across the January 2026 boundary, because an alert you cleared under a Group ID and one you clear today under a Unique ID need to remain the same case. For what follows once a match is confirmed, see UK sanctions compliance.

Screening the UK Sanctions List with dilisense

With dilisense you can search OFAC's SDN and consolidated lists, alongside EU, UN, UK and other sources, through a single API. The data updates hourly and every match is traceable to its origin.