As we’ve talked about previously, from 28 January 2026, the UK government consolidated its sanctions framework.

The UK Sanctions List (UKSL), maintained by the Foreign, Commonwealth & Development Office (FCDO), is now the single authoritative source for all UK sanctions designations. The OFSI Consolidated List of Asset Freeze Targets. which has sat alongside the UKSL since the UK’s post-Brexit sanctions regime came into force in December 2020, has been retired and will no longer be updated. It remains accessible online for historical reference only.

For many law firms, the immediate question is: does this change anything in practice? The short answer is yes, and for some firms, the gap between what they currently do and what they now need to do may be wider than expected.

Why the change was made

The UK’s post-Brexit sanctions regime was built on two parallel lists. The UK Sanctions List, created under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA), covered all UK sanctions designations – financial, immigration, trade, and transport. The OFSI Consolidated List, maintained separately by HM Treasury’s Office of Financial Sanctions Implementation, captured only those subject to financial sanctions, including asset freezes.

Maintaining two lists created duplication, confusion, and unnecessary compliance burden for regulated firms. Following a cross-government review of sanctions implementation and enforcement announced in May 2025, and after consulting industry, the government concluded that a single list would reduce complexity and improve data accuracy. The UKSL became the sole source at 9am on 28 January 2026.

What has technically changed — and why it matters

The practical implications go beyond updating a bookmark. The most operationally significant change relates to how designated persons (DPs) are identified in screening systems. Previously, each DP carried an OFSI Group ID, which many third-party screening tools and compliance systems used as their primary identifier. Under the new system, newly designated persons will only carry a UK Sanctions List Unique ID. Any screening tool, feed, or internal system that has not been updated to use the new identifier will fail to identify new designations entirely.

The GOV.UK guidance is explicit on this point: firms that use the OFSI Group ID in their reporting systems, licence applications, or automated screening feeds need to update those systems to use the UK Sanctions List Unique ID for any persons designated after 28 January 2026. Historic OFSI Group IDs for persons designated before that date will remain valid and are retained within the UKSL, but new designations will not carry them.

For firms using specialist third-party screening providers, the immediate action is to confirm with your supplier whether their data has been migrated and updated. Do not assume this has happened automatically.

The fuzzy matching issue and a cautionary tale

The UK Sanctions List supports ‘fuzzy matching’, meaning it can identify partial or approximate name matches. This is particularly important where names have been transliterated from non-Roman scripts i.e. Cyrillic, Arabic, and Chinese in particular, where the same name can appear in multiple different spellings depending on the transliteration method used.

The SRA’s sanctions enforcement update published alongside the guidance refresh highlights a sobering example.

A bank was fined £160,000 by OFSI after a designated individual successfully opened an account because a sanctions screening search failed to identify them due to variations in how their Russian Cyrillic name was transliterated into the Latin alphabet. Notably, the individual held a British passport,  reinforcing that sanctions risk is not always visible and cannot be assessed on the basis of nationality or appearance.

The SRA’s updated guidance on the UK Sanctions Regime, revised on 28 January 2026, emphasises that firms should actively configure their screening tools to use fuzzy matching capability, and that staff using and relying on screening systems should understand both their capabilities and their limitations. Date of birth, where available, should be used alongside name matching to reduce false positives and increase confidence in positive results.

HM Government’s own free UK Sanctions List search tool supports fuzzy logic, and for firms that cannot currently afford or justify a commercial screening solution, this is a legitimate starting point. However, firms should be aware that automated tools can struggle with indirect or structural connections: they may not reliably identify subsidiary entities of designated persons, or connections based on control rather than share ownership.

Staff screening is now expected

One of the most significant additions in the SRA’s updated sanctions guidance is the explicit expectation that firms should carry out sanctions screening of staff as part of the onboarding process,  not just of clients. This aligns sanctions screening with the kind of due diligence that firms already apply for AML purposes, and reflects a broader regulatory expectation that compliance culture should extend inward, not just outward.

Firms that have historically limited screening to client onboarding will need to review their HR procedures. Staff screening should be against the UK Sanctions List and conducted consistently, not just for new joiners in client-facing roles, but across all roles with access to client matters or funds.

Contractual documents and saved links

Beyond screening tools and HR processes, firms should also review any contractual documents or operational procedures that contain embedded references to the OFSI Consolidated List. These should either be updated to reference the UK Sanctions List directly, or drafted broadly enough to capture the UKSL by implication. Any saved links or bookmarks to the OFSI search tool should also be replaced with links to the UKSL and its search tool on GOV.UK.

This includes template engagement letters, retainer agreements, or compliance policies that describe which lists the firm screens against. An outdated reference is not merely an administrative error; it could create ambiguity about what your firm’s compliance obligations are and whether you are meeting them.

Ongoing monitoring

The transition to a single list does not affect the fundamental obligation to screen on an ongoing basis, not just at onboarding. Sanctions designations can be added or varied without notice. Firms with significant international or cross-border work should be subscribed to the joint UK sanctions email alert service offered by the FCDO, OFSI, and OTSI, which provides timely updates on additions and changes to the list.

The SRA has been clear in its updated guidance: the sanctions regime operates on a basis of strict liability. There is no defence of ignorance. If a firm provides services to a designated person, or handles funds that should have been frozen, the consequences can include criminal liability, civil penalties, and regulatory sanction  regardless of intent.

Actions for your firm

• Update all internal policies, procedures, and training materials to reference the UK Sanctions List only – remove all references to the OFSI Consolidated List.
• Verify with your third-party screening provider that their system has been updated to use the UK Sanctions List Unique ID, not the legacy OFSI Group ID.
• Ensure your screening tool supports fuzzy matching, and that staff understand how to interpret partial match results.
• Update HR onboarding procedures to include sanctions screening of new staff against the UKSL.
• Replace any saved links or bookmarks to the OFSI search tool with the current UKSL search tool on GOV.UK.
• Review any contractual documents or retainer templates that reference the OFSI Consolidated List and update them accordingly.
• Subscribe to the joint UK sanctions email alert service to receive timely notification of new designations and variations.