A comprehensive guide to the UK sanctions list

Like most countries, the UK issues a range of sanctions against individuals, groups, and other states to achieve certain economic or diplomatic outcomes. Sanctions form a major element of the UK’s foreign policy. As a significant political and economic power, the UK often plays a prominent role in shaping the international sanctions landscape. 

This guide will outline: 

• The types of sanctions the UK issues.  
• The regulations under which sanctions are issued in the UK. 
• The challenges of UK sanctions compliance. 
• How UK firms can comply with sanctions. 

Types of sanctions imposed by the UK

The UK government can impose several kinds of sanctions, with responsibility for implementation and enforcement split across government departments depending on the type. These include:

• Trade sanctions: These ban the import and/or export of goods, technology, or services relating to them, with arms embargoes being one common example. Trade sanctions in the UK are implemented by the Department for Business and Trade, while the Office of Trade Sanctions Implementation (OTSI) assists firms with compliance and issues licenses for sanctions exceptions. OTSI enforces civil trade sanctions, while His Majesty’s Revenue and Customs (HMRC) is responsible for criminal enforcement. 
• Economic sanctions: These include asset freezes plus other restrictions on investment and financial services. Financial sanctions are enforced on a civil level by the Office of Financial Sanctions Implementation (OFSI), which is part of His Majesty’s Treasury (HMT). OFSI helps firms understand their obligations and monitors for compliance breaches. It can also refer cases to law enforcement, such as the National Crime Agency (NCA), for criminal enforcement. 
• Immigration sanctions: Also known as travel bans, these ban designated individuals from entering or remaining in the UK and are enforced by the Home Office. 
• Aircraft and shipping sanctions: Imposed by the Department for Transport, these comprise restrictions on the movement, ownership, and registration of ships and aircraft. 

Sanctions regulations in the UK 

The UK’s sanctions framework consists of various pieces of legislation and frequently updated lists and regulations. The key laws involved are: 

• The Sanctions and Anti-Money Laundering Act 2018: Designed to allow the UK to uphold its own sanctions after leaving the EU, the Sanctions Act is the legal basis for the issuing and enforcement of all sanctions in the UK. 
• The Export Control Order 2008: This allows the government to issue trade restrictions and establishes the penalties for any violations.  
• The Anti-Terrorism, Crime and Security Act 2001: This established the UK’s asset seizure regime for offenses specifically relating to terrorism. 

Like all members of the United Nations (UN), the UK implements sanctions issued by the intergovernmental body, like all members of the intergovernmental organization. Details of these can be found on the UN Security Council (UNSC) Consolidated List. The UK government also maintains a unilateral sanctions list, known as the UK Sanctions List, which contains details of all sanctions applied under the Sanctions Act. OFSI oversees the Consolidated List of Asset Freeze Targets, which lists all entities subject to financial sanctions. 

Officially, the UK’s sanctions framework consists of several distinct sanctions ‘regimes’. These can either be geographic, targeting specific countries, or thematic, targeting individuals and entities for offenses of a particular nature. For example, as of November 2024, the UK currently operates geographic sanctions regimes against Russia, Belarus, and Iran, and thematic regimes relating to cyber activity, human rights violations, and counter-terrorism. All of these are included on the UK Sanctions List and administered under the Sanctions Act. 

The UK often acts in parallel with other nations, particularly its geopolitical allies, when issuing sanctions. In 2024, for example, it issued numerous coordinated sanctions against Russia with its partners in the G7 group. The UK’s human rights-related sanctions reflect similar “Magnitsky-style” regimes (named after Russian lawyer Sergei Magnitsky, who died from mistreatment in prison after revealing tax fraud by officials) implemented by other Western countries. Introduced in 2012, the United States’ original Magnitsky Act enabled the US to target the individuals responsible for Magnitsky’s death, while the subsequent Global Magnitsky Act (2016) allowed it to impose sanctions against human rights abusers anywhere in the world.  

However, firms operating across multiple jurisdictions should remain aware of the details of all relevant sanctions regimes rather than assuming compliance with one country’s sanctions framework equates to compliance with another’s. 

The consequences of sanctions breaches

The body responsible for enforcing sanctions depends on the nature of the sanctions, as specified above. However, under the Sanctions Act, breaches can result in severe civil or criminal penalties. Monetary penalties for breaches of financial sanctions can reach up to whichever is higher out of £1m or, where the breach can be linked to specific funds, 50 percent of the value of those funds. Breaches can also result in imprisonment for up to ten years in the case of trade sanctions or seven years for financial sanctions. Embargoed goods being traded without the necessary license will be seized. 

The Financial Conduct Authority (FCA), the UK’s main financial regulator, can fine firms up to 40 percent of their income if it identifies weaknesses in their sanctions compliance procedures. In 2024, the FCA issued multi-million-pound penalties to high-profile FIs. 

In 2022, Strict Liability was introduced for civil monetary penalties in the UK. This means penalties can be issued in cases where OTSI or OFSI believe, on the balance of probabilities, that a breach has occurred without having to establish whether it was deliberate. Given that firms can effectively be punished for inadvertent sanctions breaches, they should proactively take steps to ensure compliance. 

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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UK sanctions compliance challenges 

The complexity of the financial landscape and the sanctions environment mean that sanctions compliance is rarely straightforward for firms. These are some of the most common compliance challenges UK businesses can face:  

• Frequent new designations: In its 2022–23 annual review, OFSI stated it had added 800 people to the Consolidated List of Asset Freeze Targets, which makes up only one type of sanction issued by the UK. Firms must keep up with changes to sanctions lists to avoid accidentally doing business with sanctions targets. 
• Understanding beneficial ownership: A common sanctions evasion technique involves designated entities hiding their identities in a complicated web of corporate structures, including shell companies and proxy accounts. Firms need to be able to identify the ultimate beneficial owner (UBO) of an account to prevent evasion attempts. 
• Data inconsistency: To correctly screen for sanctioned entities, FIs may need data beyond just names, such as addresses or dates of birth. However, the data included on sanctions lists is not always complete or uniformly formatted, making screening problematic for firms.  
• The strain on resources: Particularly for smaller firms, investing in sanctions expertise and identifying the most cost-effective screening tools can pose challenges. FIs must find solutions to balance compliance with business growth.

How to comply with UK sanctions

UK businesses must include sanctions considerations in their anti-money laundering and countering the financing of terrorism (AML/CFT) compliance programs, ensuring they can screen against the UK Sanctions List and the UNSC Consolidated List. Any firm’s sanctions compliance program should include these steps: 

• Carry out risk assessments: Firms should base their sanctions policies, including due diligence levels, on their risk profile, taking into account customer, geographic, and product-based risks. 
• Understand who your customers are: When onboarding new customers, FIs should verify their identities, which includes establishing UBO where necessary, and screen them against sanctions lists. 
• Continue to monitor customer profiles: Given the frequency of new sanctions designations, firms should continue to monitor customers beyond the onboarding stage to check whether they have recently been added to any relevant sanctions lists. 
• Screen customer payments: In addition to screening their customers, firms must check individual payments to detect the involvement of any sanctioned entities outside their customer base. Ideally, however, this should not come at the cost of smooth and efficient payment experiences for customers. 
• Monitor transactions on an ongoing basis: In case any sanctions targets remain undetected in customer or payment screening, firms should include a focus on sanctions in their transaction monitoring solutions to detect any suspicious behavior. For example, a series of unexplained transactions to a high-risk jurisdiction may be a red flag for sanctions evasion. 
• Report suspicious transactions: If a firm has reason to believe a transaction is linked to a sanctions breach, it should report it to the NCA using a suspicious activity report (SAR). Additionally, trade sanctions breaches should be reported to OTSI, and financial sanctions breaches to OFSI. 
• Use advanced technology: Firms can ease the burden of sanctions compliance by using specialist screening technology. They should adopt automation in a targeted way, for example, in data collection and analysis, so compliance analysts are free to devote their time to the more complex, higher-risk parts of the compliance process. 

Advanced sanctions screening solutions for UK firms

Sanctions compliance depends on quality data across all stages of the customer lifecycle, from onboarding to payment screening. Here are three ways our proprietary data goes above and beyond to prime firms for optimized regulatory compliance: 

• Updates in real time: Our systems use cutting-edge AI to perform constant checks on sanctions lists, meaning firms receive updates in under an hour, often before changes are even made public by regulators. 
• Enhanced accuracy: ComplyAdvantage’s data allows firms to minimize false positives with highly accurate data. Our machine learning systems validate matches by compiling disparate data into structured profiles with clear, traceable sources. 
• Market-leading coverage: Sanctions-related data goes beyond the names of sanctioned individuals to include entities related to or controlled by them, giving firms peace of mind and enhanced protection from the consequences of breaches.