UK Sanctions List: What Accountants and Law Firms Should Check
In brief: The UK sanctions list identifies people, entities, ships, and other targets subject to UK sanctions measures, and firms should use it as part of onboarding and ongoing monitoring.
Key points
- Use official UK sanctions sources rather than copied lists where possible.
- Screen the client, beneficial owners, controllers, and relevant third parties.
- Record the match review, not just the fact that a search was run.
What is the UK sanctions list?
The UK sanctions list is the official list of designations made under UK sanctions regulations. It is published by the UK government and should be used alongside the OFSI consolidated financial sanctions list when screening clients and matters.
The official source is GOV.UK's UK sanctions list. For financial sanctions, OFSI also publishes the consolidated list of financial sanctions targets.
Who should be screened?
In professional-services work, screen more than the billing name:
- Individual clients.
- Company clients.
- Directors and partners.
- Persons with significant control and ultimate beneficial owners.
- Trustees, settlors, protectors, or beneficiaries where relevant.
- Third-party funders or connected parties where the matter requires it.
How to review a possible match
Check name, date of birth, country, address, identifiers, ownership, aliases, and the source list. A false positive should be documented. A possible true match should be escalated quickly and handled according to the firm's sanctions policy.
Evidence to keep
Keep the search date, source, search terms, results, match-review notes, decision, reviewer, and any external advice or licence consideration.
This guide is general information for UK regulated firms. Sanctions change quickly, so always check the relevant official list or get specialist advice before making a client decision.