Tomorrow (28/01/26) - UK Single Sanctions List — but a Separate Russia Specific list will still exist!!

FROM 28 JANUARY 2026,

• From this date, the UK Sanctions List (UKSL) will become the sole authoritative source for all UK sanctions designations.
• The OFSI Consolidated List of Asset Freeze Targets will be retired and will no longer be updated. This is a material operational and compliance change for all firms conducting sanctions screening.
• Although a separate Russia-specific list for certain financial and investment restrictions will continue to exist, meaning firms must still account for two UK sanctions-related lists in some scenarios.(READ MORE BELOW)

Key points you need to know ABOUT the UK Sanctions List (UKSL)

• The UK Sanctions List becomes the only official list for UK sanctions designations.
• The OFSI Consolidated List and its search tool will stop receiving updates from 28 January 2026.
• New designations will no longer use OFSI Group IDs — firms must instead use the UKSL Unique ID.
• Historic OFSI Group IDs remain valid only for pre-2026 designations but should not be relied on going forward.
• Firms must ensure policies, systems, vendor tools, contractual wording and reporting workflows are updated to reflect the UKSL as the authoritative source.
• Most sanctions breaches arise not from intent, but from outdated systems or fragmented processes. Regulators expect firms to demonstrate that changes are implemented, tested, and embedded across the organisation.
• [gov.uk], [skadden.com]
• Although presented as an administrative simplification, this shift represents a material change in compliance affecting systems, governance, data sourcing, screening processes, and regulatory risk across UK financial and non-financial businesses.

WARNING RUSSIAN LIST

• Importantly, firms should note that the UK will continue to operate a separate Russia-specific list of FINANCIAL AND INVESTMENT RESTRICTIONS, as confirmed in government guidance. [assets.pub…ice.gov.uk]
• The UK publish a separate Russia-specific list because it governs special financial and investment restrictions rather than standard sanctions designations.

The Russia-specific list is not a designation list — it is a thematic restrictions list

• The list that continues to exist — the Russia: persons named in relation to financial and investment restrictions list — is not a designations list.
• It is a special-purpose list tied to specific Russian regulations, and it has historically sat outside the normal designation system. [assets.pub…ice.gov.uk]

Why does it remain separate?

• Because this Russia-specific list is
• Not about sanctioning individuals through designation,
• But about identifying persons affected by special financial/investment rules under Russia-related regulations.
• It supports operational restrictions, not designation-based prohibitions.
• This is why it is not merged into the UK Sanctions List.

In practice: One designation list + one Russia restrictions list

This is where the wording becomes confusing.

The UK now has:

1. One official designation list

• UK Sanctions List (UKSL) → the only authoritative list of sanctioned persons/entities. [gov.uk]

2. One specialist regulatory list (Russia-specific)

• Still published separately
• Exists for financial and investment restrictions only [assets.pub…ice.gov.uk]

So why still “two lists”?

• Because firms with exposure to Russia or Russia-linked financial/investment activity must review the Russia list in addition to the UKSL.
• However, the government’s “single list” messaging refers specifically to sanctions designations, not every supplementary sanctions dataset.

What this means for compliance teams

• For core sanctions screening:
• Use only the UK Sanctions List.
  This is the authoritative list and replaces the OFSI Consolidated List.
• For Russia‑related financial/investment restrictions:
• You must continue checking the Russia‑specific list where relevant.
• Why this matters operationally:
• Screening tools must be pointed at the UKSL, not the OFSI Consolidated List.
• Workflows involving Russia-related financial/investment rules must retain the separate Russia dataset.
• Firms must update policies to reflect the UKSL as the authoritative source, while maintaining references to the Russia restrictions list where applicable.

Read more:

The UK Sanctions List becomes the sole official list for UK sanctions designations

Until now, UK sanctions designations were split across two lists:

• UK Sanctions List (FCDO) — covering all types of sanctions
• OFSI Consolidated List (HM Treasury/OFSI) — covering financial sanctions only [gov.uk], [skadden.com]

This dual-list regime led to confusion, duplication of effort, and inconsistent data sourcing across the industry. The government’s cross-departmental review concluded that a single list will streamline implementation and reduce errors. [natlawreview.com], [assets.pub…ice.gov.uk]

Key change from 28 January 2026

• The OFSI Consolidated List and its search tool will no longer be updated. [gov.uk]
• The UK Sanctions List becomes the sole official list for UK sanctions designations. [skadden.com]
• OFSI Group IDs will no longer be assigned to new designations; firms must now rely on the UKSL Unique ID system. [globalsanctions.com]
• Historic OFSI Group IDs will remain only for pre-2026 designations, but continued reliance on them is discouraged. [globalsanctions.com]

Crucially, Not a complete consolidation

Government materials confirm that a separate, Russia-specific list of persons subject to financial and investment restrictions will continue to exist. This means firms screening for Russia-related exposure will still need to reference multiple sources even after the Consolidated List is retired. [assets.pub…ice.gov.uk]

Regulatory expectations and risks

Regulators, including the FCA, SRA, and other supervisors, expect firms to:

• Update systems and controls promptly
• Demonstrate testing, governance and documented ownership
• Avoid reliance on outdated references to the OFSI Consolidated List
  (which will be visible on GOV.UK, but clearly marked as unmaintained) [assets.pub…ice.gov.uk]

Sanctions breaches rarely arise from wilful evasion. They commonly result from:

• Misaligned workflows
• Outdated screening tools
• Fragmented ownership of sanctions processes

The shift to a single list will quickly expose weaknesses where firms rely heavily on third-party screening providers without understanding the underlying data sources. [natlawreview.com]

What UK businesses should do now?

The UKSL is already live, stable and available in updated formats (CSV, TXT, PDF and more). Firms are strongly advised not to wait until 28 January to implement changes. [assets.pub…ice.gov.uk]

1. Update internal policies and procedures

Internal governance documents, risk assessments, AML/FC frameworks and sanctions manuals must clearly state that the UK Sanctions List is the authoritative source. [gov.uk]

2. Review systems and screening tools

Any tool sourcing data from the Consolidated List — or relying on OFSI Group IDs — must be upgraded.
Firms should initiate proactive conversations with third-party vendors rather than assume automatic alignment. [skadden.com], [globalsanctions.com]

3. Update identifiers and reporting workflows

From 28 January 2026:

• New designations will only carry UKSL Unique IDs
• Reporting lines, alerts, and MI dashboards must handle this change [globalsanctions.com]

4. Review contracts and transactional documentation

Any contract clauses requiring screening against the OFSI Consolidated List (a common formulation) must be amended or broadened to reference the UK Sanctions List. [skadden.com]

5. Strengthen governance and ownership

The transition presents an opportunity to address fragmented ownership.
Firms should confirm clear accountability, escalation routes and group-wide visibility over sanctions operations. [natlawreview.com]

Summary

• The UK is consolidating its sanctions architecture into a single authoritative list on 28 January 2026.
• The OFSI Consolidated List will cease to be updated thereafter.
• BUT a separate Russia-specific restrictions list will remain active, meaning the UK will continue to have two sanctions-related lists for certain purposes. [assets.pub…ice.gov.uk]
• Businesses must urgently update systems, governance, and documentation to avoid regulatory risk and screening failures.

Sources

• UK Government: Move to a single list for UK sanctions designations (28 January 2026) [gov.uk]
• Skadden: UK moving to a single list for sanctions designations (Jan 2026) [skadden.com]
• Proskauer (NatLawReview): FCDO/OFSI/HMT confirm Consolidated List closure (2026) [natlawreview.com]
• UK Government Webinar: “Moving to a Single List for UK Sanctions Designations” — confirms continuing Russia‑specific list [assets.pub…ice.gov.uk]
• GlobalSanctions.com: Operational impact, identifiers, and data‑source changes [globalsanctions.com]
• Bowmans: UK transition to a single sanctions list overview (2026) [bowmanslaw.com]