UK Sanctions List Consolidation

Crowell & Moring Trade Blog

Published January 28th, 2026

Detected March 1st, 2026

Summary

The UK's Foreign, Commonwealth and Development Office is consolidating its sanctions designations into a single UK Sanctions List (UKSL) effective January 28, 2026. This change aims to reduce non-compliance risk by simplifying identification of sanctioned individuals and entities, without altering the scope of sanctions or business obligations.

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What changed

Effective January 28, 2026, the UK Sanctions List (UKSL) will become the sole source for UK sanctions designations, replacing the Office of Financial Sanctions Implementation's (OFSI) Consolidated List. This consolidation, mandated by the Sanctions and Anti-Money Laundering Act 2018, is intended to simplify compliance by providing a single point of reference for sanctioned entities, thereby reducing the risk of non-compliance. While the format of the UKSL remains unchanged, newly designated persons will receive a Unique ID instead of an OFSI Group ID, though historic Group IDs will be retained.

Businesses and individuals subject to UK sanctions must update their internal systems to draw data exclusively from the UKSL. This transition requires proactive review of data sources to ensure continued compliance with financial sanctions obligations. Failure to update systems could lead to inadvertent non-compliance, though the document does not specify penalties for this particular change, it implies that existing sanctions penalties would apply for any resulting breaches.

What to do next

Update internal systems to use the UK Sanctions List (UKSL) as the sole source for sanctions designations.
Ensure all relevant personnel are aware of the transition from the OFSI List to the UKSL.
Verify that any systems referencing OFSI Group IDs can accommodate the new Unique ID system for newly designated persons.

Source document (simplified)

From Wednesday, 28 January 2026, the UK Sanctions List (“UKSL”), published by the Foreign, Commonwealth and Development Office, will act as the sole source of UK sanctions designations made under the Sanctions and Anti-Money Laundering Act 2018 (“SAMLA”). OFSI’s Consolidated List of Asset Freeze Targets (the “OFSI List”) and its search tool will not be updated beyond 28 January 2026.

The move to a single sanctions list is intended to simplify how businesses and individuals subject to sanction designations are identified, without altering sanctions scope or business obligations under UK law. The format of the UKSL will remain unchanged. This transition is a direct result of industry feedback received during a 2025 cross-government review, with an emphasis on removing the need to cross-reference multiple sources in hopes of reducing the risk of non-compliance.

Businesses should ensure that any internal systems which draw on the data from the OFSI List now draw from the UKSL. The UKSL will continue to be updated, and will be available in seven data formats.

In addition to these changes, any newly designated persons (DPs) subject to financial sanctions will no longer be assigned an OFSI Group ID; instead they will only have a Unique ID as an identifier. All UKSL formats will retain the historic OFSI Group ID data, meaning any historic Group IDs will continue to be valid for use.

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Crowell & Moring is a full-service international law firm that represents major businesses – both public and private – in complex high-stakes litigation, enforcement, regulatory and administrative, transactional matters, and government and internal investigations. Our Trade Law Blog features legal insight and thought-leadership affecting the industries and business reliant and affected by international trade.