ASK MAT – I’m aware there are two sanctions lists – a central one, and the other restrictions under the Russian regime – are they the same?

ASK MAT:

• I’m aware there are two sanctions lists – A CENTRAL ONE, and the other is a DEDICATED LIST  for restrictions under the Russian regime – are they the same?
• I ask because many named Russians (individuals or entities) appear on both lists.

MAT SAYS

The UK maintains a comprehensive CENTRAL sanctions framework under the Sanctions and Anti-Money Laundering Act 2018 [SAMLA], with designations organised primarily through the UK Sanctions List, which serves as the central, consolidated source for all UK sanctions across various regimes, including the one targeting Russia.

This CENTRAL list includes:

• Individuals, entities, and ships subject to measures like asset freezes, travel bans, and other restrictions, with Russia-related designations falling under the specific Russia sanctions regime.

Separately, there is a DEDICATED LIST focused on financial and investment restrictions under the Russian regime (Schedule 2 of the Russia (Sanctions) (EU Exit) Regulations 2019), which identifies "persons" (primarily organisations and entities, though the term can include individuals) subject to targeted prohibitions such as dealing with transferable securities or money-market instruments, granting loans or credit, or entering into related arrangements.

Examples from this DEDICATED LIST  include

• Major Russian entities like GAZPROM NEFT, GAZPROMBANK, PJSC SBERBANK, ROSNEFT, and VTB BANK, many of which are state-owned or operate in key sectors such as energy, finance, and defence.
• This list applies to entities incorporated anywhere (not just in Russia) if they are owned or controlled by listed parties.

However, the CENTRAL AND DEDICATED sanctions LISTS aren't always identical;

• The central UK Sanctions List encompasses a wider array of measures (e.g., asset freezes, arms embargoes, or immigration restrictions) that may apply cumulatively.
• At the same time, the dedicated Russia financial list highlights narrower, regime-specific prohibitions aimed at curbing investments and financial dealings with key Russian economic players.

For instance,

• An entity on the DEDICATED LIST faces explicit bans on UK persons providing loans or handling their securities, which stem from Chapter 2 of Part 3 and Schedule 2 of the Russia (Sanctions) (EU Exit) Regulations 2019.

Based on the current composition of the dedicated list as of February 2026, the entities appearing exclusively on this dedicated list (without a corresponding designation on the central UK Sanctions List) are:

• OPK OBORONPROM (Historic Group ID: 13120) – A Russian state-owned industrial corporation involved in defense and aerospace, subject to investment bans since 2014 but not asset freezes or other central list measures.
• TRANSNEFT (Historic Group ID: 13118) – Russia's state-owned oil pipeline operator, subject to sectoral financial restrictions but not designated for asset freezes on the central list.

This separation exists because the dedicated list focuses on targeted sectoral restrictions to limit financial flows without necessarily applying full designations like asset freezes, which are reserved for the central list.

Other reason for maintaining this separate Russia-focused dedicated financial list, despite overlap with the central one, is to

• provide clear, targeted guidance on these particular restrictions, making it easier for businesses, financial institutions, and compliance teams to identify and adhere to the investment-related prohibitions without sifting through the broader designations on the main list.
• This structure helps emphasise the UK's strategic aim to disrupt Russia's economic capabilities in sectors like energy and banking.

Legal status

• Both the central UK Sanctions List and the dedicated UK Russia financial and investment restrictions list are ultimately driven by the Sanctions and Anti-Money Laundering Act 2018 (SAMLA), which provides the overarching legal framework for UK sanctions regimes.
• SAMLA enables the creation of regulations for specific sanctions regimes, including the Russia (Sanctions) (EU Exit) Regulations 2019, which in turn establish the dedicated sectoral list under its Schedule 2.

Key Clarifications:

• Central UK Sanctions List:
• This is indeed required and consolidated under SAMLA 2018, serving as the primary source for all UK sanctions designations across various regimes (including Russia).
• It covers broad measures like asset freezes, travel bans, and other restrictions, and incorporates designations from subsidiary regulations like the 2019 Russia Regulations.
• Dedicated Russia List:
• This is a targeted sectoral list specifically outlined in Schedule 2 of the Russia (Sanctions) (EU Exit) Regulations 2019, focusing on financial and investment prohibitions (e.g., on transferable securities, money-market instruments, loans, and credit).
• However, these 2019 Regulations are secondary legislation made pursuant to SAMLA, so it's not a fully separate "law" but rather a regime-specific implementation under SAMLA's authority.
• Relationship Between the Two:
• The lists are derived from
• SAMLA is the enabling act for both,
• With the 2019 Regulations providing the detailed mechanics for Russia-specific measures.
• There is significant overlap (many entities appear on both), but the dedicated list emphasises narrower, investment-focused restrictions to facilitate compliance without duplicating the broader central list's scope.

Key Resources (Copy-Paste Friendly):

1. The UK Sanctions List - Official GOV.UK page with the consolidated list of all designated persons, entities, and ships under UK sanctions. URL: https://www.gov.uk/government/publications/the-uk-sanctions-list
2. UK Sanctions List Search Tool - Interactive search for designations across all regimes. URL: https://search-uk-sanctions-list.service.gov.uk/
3. Russia: List of Persons Named in Relation to Financial and Investment Restrictions - Dedicated list for Russia-specific financial prohibitions (updated location). URL: https://www.gov.uk/guidance/russia-list-of-persons-named-in-relation-to-financial-and-investment-restrictions
4. UK Sanctions Regimes Collection - Overview of all UK sanctions regimes, including statutory guidance. URL: https://www.gov.uk/government/collections/uk-sanctions
5. Withdrawn Russia Asset-Freeze Targets List (Archival) - Historical reference for Russia designations, now merged into the main list. URL: https://www.gov.uk/government/publications/financial-sanctions-ukraine-sovereignty-and-territorial-integrity