Syed Rahman of Rahman Ravelli outlines the change and the implications for businesses.
The Foreign, Commonwealth & Development Office (FCDO), the Office of Financial Sanctions Implementation (OFSI) and HM Treasury have confirmed that from January 28, 2026, the UK Sanctions List will be the sole official source of UK sanctions designations.
The decision, which means the OFSI Consolidated List of Asset Freeze Targets will close, has been made after a cross-government review. There will be no changes made to the structure of the current UK Sanctions List.
The change is one that has implications for all firms that carry out sanctions screening, third-party screening vendors that source UK designations, and non-UK businesses operating outside the UK but screening for UK exposures.
Reasons
There are a number of reasons why the move to a single list can be seen as a logical one. Having just the one list will reduce duplication. It will also remove the problems that can arise from mismatching and will streamline the process in general.
The UK government has produced guidance to help businesses prepare for - and adjust to - what is planned. It is recommending that firms switch to the single list immediately to ensure they are ready for the change on January 28 next year.
Firms need to be updating their policies to cite the UK Sanctions List as the authoritative source and ensure they keep receiving alerts from the FCDO. Any systems that are currently using the OFSI Consolidated List for sanctions screening need to be adjusted so they are working from the UK Sanctions List.
All UK Sanctions List formats will retain historic OFSI Group ID identifiers for those persons designated before January 28, 2026. These will remain valid for use in activities such as licence applications and suspected breach reporting.
The UK government will not be publishing a draft template of the UK Sanctions List, as it is already live and available for use in screening and in comparing differences between the two current lists.
