ASK MAT - What is the difference between a DELISTING & REVOCATION in sanction notices

ASK MAT: While reviewing the sanction lists, I have a question: What is the difference between delisting and revocation? Below, the ISIL is delisted, but the Russian is revoked.

MAY SAYS:-

In the UK, financial sanctions administered by the Office of Financial Sanctions Implementation - OFSI, under the Sanctions and Anti-Money Laundering Act 2018 and related regulations, DELISTING AND REVOCATION both result in the same practical outcome:

• The person or entity is removed from the sanctions list,
• Is no longer designated, and
• Is no longer subject to the associated restrictions (such as an asset freeze, trust services bans, etc.).

The key difference lies in the origin of the sanctions listing and the terminology used in official notices, reflecting the underlying legal basis:

• Delisting is the term typically used for entries originally based on United Nations sanctions regimes (implemented in UK law via specific regulations, such as the ISIL (Da’esh) and Al-Qaida (United Nations Sanctions) (EU Exit) Regulations 2019).

These listings often follow decisions by the UN Security Council or the UN sanctions committee.

• When the UN decides to remove an entry (or the UK implements such a change), the UK notice describes it as a "delisting."

In ISIL (Da’esh) and Al-Qaida above:  this is an UN-linked action

1. The March 2, 2026, notice for ISIL (Da’esh) and Al-Qaida states, "One entity has been delisted"  this aligns with a UN-linked regime (specifically, the entity AL-NUSRAH FRONT FOR THE PEOPLE OF THE LEVANT was removed following a UN decision).
2. Revocation is the term typically used for entries under UK autonomous sanctions regimes (such as the Russia (Sanctions) (EU Exit) Regulations 2019).
3. These are designations made directly by the UK government (via the Foreign, Commonwealth & Development Office - FCDO), not originating from a UN list. When the UK decides to remove such an entry (e.g., after a review, challenge, or policy decision), the notice describes it as a "revocation."

In the RUSSIAN note above, this is an autonomous UK designation

• The March 2, 2026, notice for Russia states "1 entry has been revoked"
• This refers to an autonomous UK designation - specifically, the individual John Michael Ormerod was removed

In both cases, the effect is identical:

• The asset freeze (and any other linked sanctions) no longer applies, and
• The entry is removed from the UK Sanctions List.

CONCLUSION

• This distinction in wording is mainly procedural and reflects the source of the original designation, rather than any difference in legal consequences.
• UK guidance and notices consistently use "delisting" for UN-derived regimes and "revocation" (or sometimes "removal") for UK autonomous ones.
• If you're reviewing specific sanctions lists or compliance obligations, always check the latest UK Sanctions List on GOV.UK for confirmation of status.