UK moves to single sanctions list to simplify checks
Sanctions list consolidation – a new risk for businesses
On 28 January 2026, the UK moved to a single list for all UK sanctions designations, replacing the two separate lists currently operated (the UK Sanctions List, published by the Foreign, Commonwealth and Development Office, and the Consolidated List of Asset Freeze Targets, published by the Office of Financial Sanctions Implementation (OFSI)).
The single list will remove duplication of effort and simplify checks of who is subject to UK sanctions. Following this change, the OFSI Consolidated List and its search tool will no longer be updated.
How can you report a trade sanction breach?
In line with its focus on encouraging enforcement, OTSI (Office of Trade Sanctions Implementation) has also published a blog post detailing best practices for those wishing to report breaches of trade sanctions. You can read the blog by clicking here.
A report to OTSI can be made via GOV.UK, and the report should include your contact details, details of the suspected breach, other parties’ details, and any supporting documents. The substance of the report should consider when the activity took place, the parties involved, and what specific goods or services were provided. This is an existing process, and the OTSI blog should assist companies in reporting any breach(es).
What does the publication of a single UK Sanctions List mean for businesses?
The publication of a single UK Sanctions List will have a direct impact on any internal processes that refer to either of the existing sanctions lists, or that rely on the OSFI search tool.
What steps can you take to ensure compliance?
Companies and their compliance teams will need to update their compliance processes to ensure that all checks are made against the UK Sanctions List. They should also make themselves aware of the details required to report a breach to the OTSI, ensuring that the substance of the report contains a clear narrative, details of the rules broken, and how the activity is connected with the UK.
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Please be advised that this is an update which we think may be of general interest to our wider client base. The insights are not intended to be exhaustive or targeted at specific sectors as such, and whilst we naturally take every care in putting our articles together, they should not be considered a substitute for obtaining proper legal advice on key issues which your business may face.