A guide to the HM Treasury sanctions list

His Majesty’s Treasury (HM Treasury) is the UK government’s economic and finance ministry. As part of this role, it is responsible for implementing and enforcing all UK financial sanctions. 

As one of the world’s largest economies and business hubs, the UK plays a vital role on the international diplomatic stage. It frequently imposes sanctions against foreign targets for violations of international law or threats to the country’s foreign policy or national security objectives. 

Financial sanctions consist of asset freezes, restrictions on access to financial services and markets, and bans on making funds available to sanctioned entities. They form a major part of the UK’s sanctions regime, including trade embargoes, travel bans, and aircraft and shipping sanctions. 

What is the HM Treasury sanctions list?

HM Treasury maintains the Consolidated List of Financial Sanctions Targets in the UK, which includes the names of individuals and entities subject to financial sanctions, plus other identifying information such as:

• Aliases;
• Dates of birth;
• Addresses;
• National identification numbers;
• And reasons for being added to the sanctions list. 

In addition to the Consolidated List, HM Treasury maintains a list of persons named in relation to financial and investment restrictions regarding the UK’s Russia sanctions regime. This was introduced in response to Russia’s illegal annexation of Crimea in 2014 and significantly expanded following the country’s invasion of Ukraine in 2022. The list details specific sectoral financial and investment restrictions on Russian entities, such as on dealing with transferable securities or money-market instruments. While it is a distinct sanctions list, it overlaps with the Consolidated List, with many individuals and entities appearing on both. 

As a member of the United Nations (UN), the UK is also obliged to implement sanctions passed by the UN Security Council. The HM Treasury sanctions list incorporates all UN financial sanctions targets.  

What is OFSI?

The Office of Financial Sanctions Implementation (OFSI) is the body within HM Treasury that handles UK financial sanctions. It implements and enforces these sanctions by helping firms understand their compliance obligations and responding to any breaches. OFSI has, for example, released an advisory on detecting sanctions evasion relating to the Russian Oil Price Cap and one on North Korean IT workers. 

Who has to comply with the HM Treasury sanctions list?

All UK citizens must comply with HM Treasury sanctions, whether or not they are based in Britain. Non-UK individuals, businesses, and charities must comply if they were established under UK law or if they carry out activities within UK territory. 

Consequences for non-compliance with the HM Treasury sanctions list

UK financial sanctions violations are punishable by fines of up to £1 million or 50 percent of the funds related to the breach, whichever is greater. Breaches of financial sanctions may also be criminal offenses, resulting in prison sentences of up to seven years. 

OFSI has issued significant penalties against a range of businesses, including large and high-profile organizations. Firms of all sizes must ensure they use fit-for-purpose sanctions screening solutions to avoid costly compliance violations. Since 2022, OFSI has not been obliged to demonstrate that a breach was committed knowingly before enforcing civil penalties, making vigilance even more critical for firms. 

Taking a layered approach to sanctions compliance

Learn what a layered approach to sanctions compliance looks like in practice, with a discussion on the ever-evolving sanctions landscape from our expert panel.

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Entities sanctioned by HM Treasury

The HM Treasury Consolidated List includes asset freeze targets from many of the UK’s individual sanctions regimes. Some of these regimes are geographic, targeting entities based on their location in a sanctioned state. As of November 2024, these are: 

• Afghanistan 
• Armenia 
• Azerbaijan 
• Belarus 
• Bosnia and Herzegovina 
• Central African Republic 
• China 
• Democratic People’s Republic of Korea 
• Democratic Republic of the Congo 
• Guinea 
• Republic of Guinea-Bissau 
• Haiti 
• Iran 
• Iraq 
• Lebanon 
• Libya 
• Mali 
• Myanmar 
• Nicaragua 
• Russia 
• Somalia 
• South Sudan 
• Sudan 
• Syria 
• Venezuela 
• Yemen 
• Zimbabwe 

However, other regimes are thematic and target those involved in these activities: 

• Chemical weapons proliferation  
• Cyber activity 
• Corruption 
• Human rights violations 
• Terrorism 
• Unauthorized drilling 

These regimes make up the UK’s autonomous sanctions framework and are administered under the Sanctions and Anti-Money Laundering Act. 

How to comply with the HM Treasury sanctions list

The sanctions framework operated by HM Treasury is comprehensive, frequently updated, and carries serious consequences for breaches. With this in mind, firms should take a few essential steps to ensure they are best positioned for compliance. 

• Know your customer (KYC): Under UK law, businesses are required to ask customers for certain data when entering into a business relationship, such as identifying information and the nature of their intended business. They should also screen potential customers against sanctions lists, watchlists, politically exposed person (PEP) data, and adverse media to fully understand any risks they may present. 

• Monitor for sanctions-related updates: Due diligence is not a one-time activity. Firms must monitor customers and transactions continually to detect changes that could affect their sanctions risk profile. For instance, a previously unsanctioned customer could be added to the HM Treasury sanctions list or become subject to sectoral sanctions. Employing robust payment screening and transaction monitoring systems tailored to identify potential sanctions breaches ensures businesses detect and respond to risks as they arise. 

• Check the quality of your data: Sanctions lists, including the HM Treasury Consolidated List, are updated frequently as individuals, entities, and sectors are added or removed. Using outdated, incomplete, or inaccurate customer data increases the risk of missing a match to a newly sanctioned entity or incorrectly flagging a false positive for a delisted party. Maintaining accurate and up-to-date customer records is essential for effective sanctions screening. Clean, well-structured data allows firms to track changes in real-time, improving the accuracy of matches and reducing unnecessary delays or compliance risks. 

• Automate sanctions screening where possible: Automated AML sanctions screening tools allow institutions to achieve ongoing compliance with fast-changing sanctions lists and avoid penalties. Integrated as part of a risk-based AML/CFT program, a sanctions screening tool can be used to quickly check the relevant lists and identify sanctioned customers immediately, freeing up analysts’ time for more fine-grained, higher-risk tasks. 

• Streamline remediation and reporting: Siloed data and case management systems make it significantly harder for analysts to assess sanctions risks. Rather than keeping sanctions and customer data in individually managed spreadsheets, compliance teams can use an application programming interface (API) able to integrate different platforms to optimize workloads. This allows them to create consolidated customer profiles which allow sanctions and other financial crime risks to be viewed on a single screen for maximum risk visibility. 

Empower your business with real-time updates to sanctions data

Without the right AML solution in place, sanctions screening can burden compliance teams with heavy, time-consuming workloads. 

Severe regulatory and reputational consequences for sanctions breaches make rigorous compliance procedures essential. The need for accuracy and completeness means compliance teams working with legacy solutions can find themselves burdened by heavy, time-consuming workloads. 

But sanctions compliance does not have to slow businesses down. Instead, it can work to firms’ advantage, with the right solution allowing them to receive updates and onboard customers faster than other firms. 

ComplyAdvantage’s sanctions screening software allows firms to quickly and efficiently screen customers against sanctions lists from all relevant regulators, including HM Treasury, the Office of Foreign Assets Control (OFAC), and more. Sanctions-related data allows firms to build strong relationships with regulators by going beyond minimum requirements, giving visibility into entities linked to or controlled by sanctioned entities. 

With the rate of change to sanctions lists a persistent challenge for businesses, ComplyAdvantage customers receive updates in real-time thanks to automatically refreshed sanctions data, validated by expert teams to ensure accuracy and peace of mind.