How to check the UK sanctions list
UK financial sanctions bind everyone in the UK, not only banks: dealing with a designated person’s money or assets is an offence unless a licence allows it. This guide explains where the official list is, how to search it, and how to read a match.
Where the official list is
The UK Sanctions List is published on GOV.UK by the Foreign, Commonwealth and Development Office. It names every person, organisation and ship designated under UK sanctions regulations, with the regime each designation falls under. HM Treasury’s Office of Financial Sanctions Implementation, known as OFSI, implements and enforces financial sanctions.
The list can be searched online and downloaded in full. Use the official list, or a tool that takes its data straight from it, because copies kept elsewhere can fall behind.
What the duty is
Unless a licence allows it, it is an offence to deal with the funds or economic resources of a designated person, or to make funds or economic resources available to them or for their benefit. OFSI can also impose civil penalties, and since June 2022 it has not needed to show that the person knew or suspected a breach.
The freeze reaches further than the names on the list. A company owned or controlled by a designated person is treated as covered too, even when the company itself is not listed.
How to search well
Search the full name, then the parts of it, then any other spellings. Names from other alphabets are written in English in several ways, and the list records known aliases for that reason. For an organisation, search its former names and trading names as well.
Record what you searched, when, and what came back. A record of a clean search, dated, is part of showing that the check was made.
How to read a possible match
A name that matches is not yet a person who matches. Compare the other details the list gives: date of birth, nationality, address, passport or company numbers. Most possible matches on common names turn out to be other people.
Where a match cannot be ruled out, pause the dealing and look harder before going on. Where it is confirmed, do not proceed, and report it to OFSI. Firms in regulated sectors, such as banks, accountants, lawyers and estate agents, must report to OFSI when they know or suspect a breach or hold frozen assets.
What a clean search cannot show
A clean search shows that a name was not on the list on that day. Designations change often, so the check is repeated when the list is updated or before each significant payment.
Nor can a name search show who stands behind a company. A company can be owned or controlled by a designated person who appears nowhere in its own records, which is why sanctions screening goes together with checking ownership. Dealings that touch other countries, or other currencies such as the US dollar, may also need checks against the United Nations, European Union or United States lists.