ASK MAT – I’m confused, tomorrow the UK is moving to a single sanction list, but I know there are two. Please help

ASK MAT – I’m confused, tomorrow the UK is moving to a single sanction list, but I know there are two. Please help

Mat says:-

• I understand your confusion, and you’re not wrong — both things are true.
• The situation as of tomorrow is that the UK will have
• one official list of sanctioned people (UKSL),
• but a separate Russia restrictions list still exists because it’s not a sanctions designation list — it’s a special‑rules list.

I'll try to offer a simple, clear explanation of why it feels like the UK is moving to “one list” but you still see two

1. What the UK means by “one sanctions list”

Starting tomorrow (28 January 2026), the government is removing the two designation lists we’ve all been using:

• UK Sanctions List (UKSL)
• OFSI Consolidated List

These two used to overlap, which was confusing. From tomorrow, only the UK Sanctions List will continue — this is what the government means by “moving to one list.”

2. Why do you still see a second list

• The UK also publishes a separate Russia-specific list.
• This list is not a sanctions designation list.
• It’s a thematic restrictions list — used only for Russia-related financial and investment restrictions.
• Because it serves a different purpose, it is not being merged into the UK Sanctions List.
• So the simple truth is:
• There will be ONE official sanctions designation list = → the UK Sanctions List
• But there will still be ANOTHER list for Russia-specific rules = → because it’s not a sanctions designation list

I have below, provide a simple guide below to help you

Know your sanctions: -Designation List vs Thematic Restrictions List

WHAT IS A DESIGNATION LIST?

• A designation list is the official, legal list of people or entities that the government has formally “designated” under sanctions law.
• Think of it as:
• “The official list of sanctioned people and companies.”

Key features of a Designation List:

• It contains those who are legally subject to sanctions measures, such as:
• asset freezes
• travel bans
• trade restrictions
• financial prohibitions [gov.uk], [skadden.com]
• Every individual/entity on it has been formally designated under UK sanctions regulations.
• It is the single authoritative reference used for:
• sanctions screening
• onboarding checks
• ongoing monitoring
• regulatory reporting

UK Example:

• From 28 January 2026, the UK Sanctions List (UKSL) becomes the only authoritative designation list. [gov.uk]

WHAT IS A THEMATIC RESTRICTIONS LIST?

A thematic restrictions list is not a list of designated persons. Instead, it identifies people or entities subject to specific rules tied to a theme, such as:

• Russia-related financial and investment restrictions
• Cyber measures
• Maritime/aviation restrictions
• Export controls

Think of it as: “A list of people affected by special rules, but who are not all formally sanctioned.”

Key features of Thematic Restrictions Lists:

• They do not represent full sanctions designations.
• They support special regulatory restrictions, usually narrower than a full asset freeze.
• They are created for operational clarity, not formal designation.
• They may:
• Apply only to specific sectors
• Apply only to certain types of transactions
• Require enhanced monitoring, not full sanctions screening

UK Example:

• A separate Russia-specific list (“persons named in relation to financial and investment restrictions”) will continue to exist even after the UKSL becomes the sole designation list. [assets.pub…ice.gov.uk]

This list helps firms comply with Russia-related financial/investment rules, but does not replace or duplicate the UK Sanctions List.

3. The Key Difference in One Sentence

• A Designation List = the legally binding list of sanctioned persons.
• A Thematic Restrictions List = a list of persons subject to specific regulatory rules, but not full sanctions designations.

WHY DOES THE UK STILL HAVE BOTH?

Because they serve different legal purposes:

BOTTOM LINE:

• The UK government is removing duplicate designation lists (UKSL & OFSI Consolidated List).
• But it is keeping thematic Russia restrictions lists because they serve a different regulatory function.

HOW YOU SHOULD USE EACH LIST

Use the UK Sanctions List (Designation List) for:

• All standard sanctions screening
• Onboarding and periodic reviews
• Reporting to OFSI/FCDO
• Identifying asset freeze obligations

Use Thematic Restrictions Lists for:

• Russia-related financial and investment compliance
• Specialist rules applicable to particular sectors
• Added checks in risk-based Russia workflows

CONCLUSION

• Designation List = “People who are officially banned.”
• Thematic Restrictions List = “People who trigger special rules but are not fully banned.”
• Both matter — but for different reasons.

Source

• https://assets.publishing.service.gov.uk/media/69480c531a2e540ccd8a543a/Moving_to_a_Single_List_for_UK_Sanctions_Designations_-_HMG_Webinar_17_December_2025.pdf
• https://www.skadden.com/insights/publications/2026/01/uk-moving-to-a-single-list-for-uk-sanctions-designations