IMPORTANT: Moving to a single list for UK sanctions designations

The change applies from 09:00 28 January 2026.

Under the current regime, the UK operates two lists. The UK Sanctions List (published by the Foreign, Commonwealth and Development Office) and the Consolidate List of Asset Freeze Targets (published by HM Treasury and Office of Financial Sanctions Implementation).

As of 09:00 28 January 2026, the UK will be moving to a single list for UK sanctions. The UK Sanctions List will be the only source for UK designations, the consolidated list alongside the search function will no longer be updated

Next steps for all firms (including sole practitioners)

The government advises to ensure that by Wednesday 28 January 2026, any systems that use the OFSI Consolidated List for sanctions screening purposes are instead using the data from the UK Sanctions List. Any systems that use ‘OFSI Group ID’ as an identifier will need to use the UK Sanctions List’s ‘Unique ID’ for new DPs.

It is also recommended to switch to the UK Sanctions List as your primary source of designations data now.

If you use a specialist screener or other third-party providers, you should speak to your supplier to understand the impact, if any, on data you receive. 

For more information please visit GOV UK.

For more information

Further guidance and support on risk management and other components of Money Laundering Regulations compliance is available on our AML webpage. You can also contact us on +44 (0)20 7367 1347 or via email [email protected].

Future of supervision

On 21 October 2025, the Government confirmed that the AML supervision for accountancy, legal and Trust and Company Service Provider sectors will move to a single professional services supervisor (SPSS), specifically the Financial Conduct Authority.

While this is a big shift, implementation is likely to take years. In the meantime, AAT will continue as the AML supervisor for our licensed members and carry out our normal responsibilities, including Practice Assurance Reviews and risk assessment activities. Therefore, our members must ensure full compliance with the MLR 2017. More on the consultation response can be found here.

Further guidance and support on risk management and other components of Money Laundering Regulations compliance is available on our AML webpage. You can also contact us on +44 (0)20 7367 1347 or via email at [email protected].

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