An important date for your diary - UK Sanctions lists to merge on 28 January 2026

What you need to know – and do – by then.

From 9:00 am on Wednesday 28 January 2026, the UK Government will simplify how sanctions are published by combining the two current sanctions lists into one.

What’s changing

Right now (November 2025), there are two separate lists:

1. The UK Sanctions List (UKSL) – UK Sanctions List (UKSL) – covers persons/designated entities under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA) and includes sanctions of all kinds (financial, immigration, trade, transport).
   
   
2. The OFSI Consolidated List – covers financial sanctions only.

From January 2026, the UK Sanctions List will become the single official list. This will be the only place where new designations will appear, the OFSI list will stop being updated after that date.

Why are they changing this now?

According to the guidance, the move is being made “in response to industry feedback that a single list will remove duplication of effort and simplify checks of who is subject to UK sanctions.”

The two lists have previously caused problems. Organisations had to check both lists to be confident they weren’t missing a relevant sanctions designation (financial v trade/immigration) meaning a duplication of time and effort.

By moving to a single list, the UK Government aims to reduce these risks, make screening simpler, and improve consistency.

What does that mean for COLPs and MLROs at law firms?

Whilst the news may appear to be inconsequential, there are implications for law firms. Here’s some step-by-step actions to follow and tick off your action list:

1. Confirm whether your systems currently pull data from the OFSI list and plan to switch fully to the UK Sanctions List (UKSL) before January 2026.
   
   
2. Update your internal policies, procedures, and staff training to reflect the UKSL as the only official source.
   
   
3. Sign up for FCDO sanctions alerts (you can do that here) and monitor for any data mismatches after the transition.
   
   
4. Contact your external screening and onboarding providers to obtain written assurance that they will:
   
   

• Transition all sanctions data to the UK Sanctions List and stop using OFSI list data after January 2026.
  
  
• Test and validate their screening tools to ensure accuracy and data integrity post-transition.
  
  
• Provide clear communication and implementation dates for the changeover.
  
  
• Supply updated technical or user guidance so your firm can align its internal processes and documentation.
  
  

Enderley Consulting can help you update your policies and train your teams accordingly.  Please don’t hesitate to get in touch.