From January 28, 2026, the UK Sanctions List will become the single authoritative source for all UK sanctions designations. At the same time, the OFSI Consolidated List of Asset Freeze Targets will be retired and will no longer be updated.

While this may look like an administrative tidy-up, it is actually a material compliance change with real implications for systems, controls, governance and regulatory risk across UK businesses.

Why does this change matter?

Until now, UK sanctions designations have been published across two lists:

• The UK Sanctions List, maintained by the FCDO, covering all sanctions types 
• The OFSI Consolidated List, maintained by HM Treasury, covering financial sanctions only

This dual-list system created confusion and inefficiency so the government decided to move to a single-list model, with the UK Sanctions List as the sole official source.

From January 28, 2026:

• The OFSI Consolidated List and its search tool will no longer be updated.
• The UK Sanctions List will be the only list detailing UK sanctions designations.
• New sanctions targets will no longer be assigned an OFSI Group ID, relying instead on the UKSL Unique ID.

For regulators, this simplifies expectations. For businesses, it raises the bar on execution.

Sanctions breaches rarely happen because firms deliberately ignore the rules. They happen because systems, policies and operational practice drift out of alignment.

This change will expose weaknesses where organisations rely on third-party screening tools without fully understanding underlying data sources, use embedded sanctions checks across multiple workflows and platforms or have decentralised or fragmented ownership of sanctions processes.

Supervisors such as the SRA and FCA expect firms to demonstrate that controls are not only updated, but tested, embedded and governed. If your sanctions framework still references the Consolidated List after January, that will be hard to defend.

What should UK businesses do now?

The UK Sanctions List is already live and usable. Organisations should not wait for the formal switch-off date to act.

Key preparatory steps include:

Review and update policies and procedures
Internal sanctions, financial crime and compliance documentation should clearly state that the UK Sanctions List is the authoritative source for UK sanctions screening. References to the OFSI Consolidated List should be removed or revised.

Assess systems and screening tools
Any system that currently sources data from the OFSI Consolidated List, or relies on OFSI Group IDs, will need updating. This applies to in-house tools and third-party providers. Firms should actively engage with vendors to confirm readiness rather than assume the change will be handled automatically.

Update identifiers and reporting workflows
From January 2026, newly designated persons will only have a UKSL Unique ID. Systems and reporting processes must be able to accommodate this. While historic OFSI Group IDs will remain valid for older designations, reliance on them going forward is a risk.

Review contracts and transactional documents
Many agreements include obligations to screen counterparties against UK sanctions or to notify on designation. If these provisions explicitly reference the OFSI Consolidated List, they should be updated or drafted broadly enough to capture the UK Sanctions List.

Strengthen governance and ownership
This is an opportunity to test whether sanctions compliance is truly firm-wide, or siloed across teams and systems. Clear ownership, escalation routes and accountability will matter if issues arise.

What about enforcement? 

At the same time as this structural change, UK sanctions enforcement continues to evolve. Regulators are increasingly focused on:

• Evidence-based compliance
• Quality of controls, not just policies
• Firms’ ability to adapt to regulatory change effectively

In that context, failing to prepare for a well-signposted change like this is likely to be viewed as a governance failure, not a technical oversight.

By the end of this month, there will be no question about where UK sanctions data comes from. There will be one list, one source of truth and one clear regulatory expectation.

For UK businesses, this means systems, contracts and controls should be ready when the old list disappears. If this change hasn’t already been mapped across your tools, procedures and governance, it is worth addressing now.

Economic sanctions have been growing increasingly complicated in recent years. As events in Russia, Iran, China and other countries grab global headlines, businesses are struggling to stay on top of changes. Our online sanctions compliance courses give your staff the tools they need to understand and comply with sanctions requirements in these volatile times. Try it here.