Typically imposed in response to serious issues such as human rights violations, breaches of international law, terrorism, or acts of aggression, sanctions are one of the most visible tools governments use to influence global events and behaviour.
At their simplest, sanctions are legal restrictions imposed on individuals, companies, ships, and even entire countries. These restrictions can cover financial dealings, trade, immigration, or transport, and they are designed to prevent illicit activity, enforce foreign policy, or respond to breaches of international law.
The UK’s response to the conflict between Russia and Ukraine offers a clear example: in recent years, a wave of asset freezes, trade restrictions, and travel bans targeted individuals, oligarchs, and entities linked to the Russian regime and its invasion of Ukraine.
Historically, UK sanctions information has been split between two main sources. The first is the UK Sanctions List (UKSL), managed by the Foreign, Commonwealth and Development Office. Since its launch in 2010, the UKSL has detailed all designations made under the Sanctions and Anti-Money Laundering Act 2018, covering financial, trade, and other types of sanctions.
The second source has been the OFSI Consolidated List, overseen by the Office Financial Sanctions Implementation. This list focused exclusively on financial sanctions and is widely used by regulated firms for screening purposes.
Now, the UK government is changing the way it presents these designations. From Wednesday 28th January 2026, all sanctions will be consolidated into a single UK Sanctions List (or UKSL), replacing the dual-list system that has long caused duplication and confusion for compliance teams.
While this move promises to simplify processes for AML compliance professionals, it also requires careful preparation to ensure your firm is not caught short.
What is changing?
From 28th January 2026, the UK will consolidate all sanctions information into a single, unified source: the UK Sanctions List. The OFSI Consolidated List will cease to be updated, and its dedicated search tool will no longer be supported.
For new designations, the OFSI Group ID will be retired. Moving forward, each designated person will be identified solely by a ‘Unique ID’ within the UKSL. While historic OFSI Group IDs will remain valid indefinitely for records and reports related to designations made before this transition, new designations will be given a Unique ID within the UKSL.
The UK Sanctions List will be upgraded in later in January 2026 with fuzzy search tools, ranked results, highlighted matches, and improved downloads.
Why is the UK consolidating the sanctions lists?
The move is in response to consistent feedback from industry. Compliance teams have often highlighted the inefficiencies of managing two separate lists. By consolidating into a single source, the UK government aims to simplify checks, reduce duplication of effort, and provide a more straightforward point of reference for firms.
From a strategic perspective, this also aligns with the UK’s broader approach to sanctions compliance: a single list reduces the risk of errors, ensures uniformity in reporting, and streamlines interactions with regulatory bodies.
For compliance teams already stretched with complex customer screening and onboarding, this reduction in administrative overhead is likely to be significant.
What does it mean for AML compliance professionals?
For teams conducting sanctions screening as part of Know Your Customer (KYC) and Know Your Business (KYB) checks during client onboarding, this change could impact your workflows, reporting and tech stack.
While the move to a single sanctions list reduces ambiguity and duplicated efforts, it doesn’t reduce the workload of screening itself, especially if checks are being carried out manually. Manual screening already takes time, while designations on sanctions lists only continue to grow in response to geopolitical change.
Moreover, any automated sanctions screening tools, either proprietary or from third-party providers, should be checked to confirm they are receiving and providing you with the correct information.
Practical steps to take now
With just over a fortnight until the consolidated UK Sanctions List comes into force and the OFSI Consolidated List is formally retired, this is a timely moment to step back and take a hard look at how defensible your sanctions screening really is.
In recent years, sanctions have shifted quickly and often without warning. When something goes wrong, regulators tend to focus less on intent and more on evidence. Being able to show that your processes were based on the correct source, applied consistently, and properly documented matters just as much as the outcome itself.
Start by auditing how your organisation currently uses sanctions data in practice, not how it is described in policy. Look closely at onboarding checks, screening, periodic reviews, and investigations. Pay particular attention to any dependencies on the OFSI Consolidated List, including references in case management systems, alert notes, internal guidance, or reporting templates.
If you rely on third-party screening tools or data providers, now is the time to engage with them directly. You should be clear on how they are handling the shift to the UKSL Unique ID, and whether any system updates, configuration changes, or internal approvals are required on your side.
Finally, validate your end-to-end process under the new UK Sanctions List. Running a mock sanction hit using a recent designation is one of the simplest ways to test whether your screening, escalation, and reporting still stack up. Follow the case through exactly as you would in a live scenario. Check that the correct identifiers are captured, timestamps reflect when the designation was identified, and supporting evidence clearly shows which version of the list was used. These details are often what regulators focus on when assessing how well your controls work under pressure.
Conclusion
The move to a single UK sanctions list simplifies where compliance teams look, but it doesn’t remove the responsibility to keep screening, monitoring, reporting, and internal processes aligned with current designations.
For AML compliance teams, this change is reminder that sanctions compliance lives or dies by accurate data and getting it wrong can lead to regulatory enforcement, financial penalties, reputational damage, and the risk of enabling sanctioned individuals and entities to commit serious crimes.
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