Consolidating the Consolidated List: the UK Moves to a Single Sanctions List

Key takeaways:

• From 28 January 2026, the UK Sanctions List will be the only sanctions list which details sanctions designations published by the UK government.
• Businesses should take proactive steps to review and amend internal policies, procedures and/or internal work instructions to ensure compliance with the UK Sanctions List.
• Any transactional documents or agreements entered into with counterparties that include references to the OFSI Consolidated List of Asset Freeze Targets should: (i) be updated to reference the UK Sanctions List; or (ii) ensure the relevant provisions are drafted sufficiently broadly so that coverage of the UK Sanctions List is implied.

Background

Following the UK’s decision to leave the European Union (EU), the UK created its own autonomous sanctions regime which came into force on 31 December 2020 under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA).

As part of the new regime established under SAMLA, the UK Sanctions List and the Consolidated List of Asset Targets (the Consolidated List) were created to provide a comprehensive list of individuals, entities and assets (e.g. vessels) sanctioned under the UK sanctions regime.

Since its launch, the UK Sanctions List has served as the primary record for sanctions designations made under SAMLA, as well as individuals and entities subject to measures imposed by the United Nations Security Council. The UK Sanctions List is published and maintained by the Foreign, Commonwealth and Development Office, which specifies who is designated and the type of sanction applicable (e.g. financial, immigration, trade and/or transport sanctions).

In contrast, the Consolidated List provides information on persons specifically subject to an asset freeze under SAMLA and United Nations sanctions regimes. It is maintained in alignment with the UK Sanctions List by the Office of Financial Sanctions Implementation (OFSI).

Reason for Consolidation

The UK government solicited industry feedback during its ‘Cross-government review of sanctions implementation and enforcement’.¹  The feedback indicated serious concerns about the confusion and duplication of compliance work caused by maintaining two separate sanctions lists. Responding to these concerns, and in line with efforts to streamline the UK’s sanctions regime, the government announced that, as of 28 January 2026, the UK Sanctions List will be the only authoritative sanctions list which details all UK sanctions designations. According to the government, replacing the UK’s dual-list system will improve systemic efficiencies, provide greater clarity and reduce the administrative burden of compliance for industry.

As a result of these changes, the Consolidated List, and its associated search tool will cease to be updated from 09:00 GMT on 28 January 2026.

Implications and Next Steps

The changes highlighted above will not only impact UK businesses, but also non-UK businesses who may have exposure to UK sanctions and therefore screen for compliance with UK sanctions.

While the switch to a single UK sanctions list will take place on 28 January 2026, there are steps that businesses should take now in preparation. We recommend the following:

• Update internal policies and procedures: Ensure that internal policies and procedures highlight the introduction of a single UK sanctions list effective 28 January 2026. Internal policies and procedures should also make clear that the UK Sanctions List will be the only authoritative UK sanctions list against which screening checks should be conducted. The UK Sanctions List is currently live; therefore, companies should adapt now and ensure that sanctions screening is conducted against the UK Sanctions List going forward. In addition, companies should look to amend internal policies, procedures and/or internal work instructions by removing any references to checking the Consolidated List.
• Touch base with screening providers: Businesses should touch base with screening providers (if applicable) to ensure that no further steps need to be taken to ensure that screening from a UK perspective is conducted against data derived from the UK Sanctions List. While we would expect this to happen automatically, it will be prudent to confirm with third party providers that this is the case. 
• Update internal screening feeds: Where businesses handle sanctions screening in-house, all internal compliance systems, feeds, tools and manuals need to be updated to ensure that screening from a UK perspective is conducted against the UK Sanctions List only. In addition, any reporting systems need to be updated to reflect the new identifier for UK sanctions targets—the “Unique ID”­—as targets will no longer be identified with a “OFSI Group ID”. From 28 January 2026, new targets will not be assigned a “OFSI Group ID” and will only be tagged with a “Unique ID”. However, the UK Sanctions List will include “OFSI Group ID” identifiers for those persons designated prior to January 28, 2026, as these historic Group IDs will remain valid for use in licence applications, frozen asset or suspected sanctions breach reporting.
• Review contractual terms: Businesses will also need to ensure that any transactional documents or agreements entered into with counterparties that include references to the Consolidated List are either: (i) updated to reference the UK Sanctions List; or (ii) the relevant provisions are drafted sufficiently broadly that coverage of the UK Sanctions List is implied (e.g. a definition of “Sanctions List” which includes (but is not limited to) the Consolidated List). Specifically, any obligations requiring a counterparty to screen against UK sanctions or to notify in the event of designation under UK sanctions should ensure that these obligations are unaffected by a move to a single UK sanctions list.

1 UK Government, ‘Cross-government review of sanctions implementation and enforcement’.