January 28, 2026

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by: kiran

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Tags: "Regulation"

One List, One Standard: The UK’s New Sanctions Framework from January 2026

As of 28 January 2026 at 9:00 a.m., the UK has introduced a fundamental change to its sanctions regime. The long-standing dual-list approach has been replaced with a single, authoritative sanctions list, marking a further step in the evolution of the UK’s post-Brexit regulatory framework.

While the change is designed to simplify sanctions compliance, firms should not underestimate the operational and governance implications. Screening systems, internal policies, and contractual language will all need careful review ahead of the transition.

A move away from duplication

Since Brexit, the UK has maintained two parallel sanctions lists:

  • The UK Sanctions List, covering all UK sanctions designations
  • The OFSI Consolidated List, focused exclusively on financial sanctions

From January 2026, this distinction will fall away. The UK Sanctions List, published by the Foreign, Commonwealth and Development Office (FCDO), will become the sole authoritative list for all UK sanctions designations.

The OFSI Consolidated List will no longer be updated. However, historic identifiers will remain valid for licence applications and asset freeze reporting, ensuring continuity for existing cases.

This reform reflects the UK government’s intention to streamline sanctions implementation, reduce duplication, and create a more coherent framework for firms operating across multiple sanctions regimes.

What’s changing in practice

The move to a single list brings several important changes that firms need to understand:

The UK Sanctions List will replace the OFSI Consolidated List as the definitive source for all UK sanctions designations.

  • The change applies across all sanctions types, including financial, immigration, trade, and transport sanctions.
  • Individuals and entities designated prior to 28 January 2026 will retain their historic OFSI Group IDs.
  • New designations made after this date will use the UK Sanctions List Unique ID as the primary identifier.

These changes follow the UK government’s 2025 cross-government review of sanctions enforcement, which concluded that a single list would:

  • Simplify sanctions screening, particularly where non-financial sanctions apply
  • Reduce duplicated compliance effort
  • Improve consistency in data referencing across government and industry

Firms submitting licence applications or asset freeze reports may continue using OFSI Group IDs for historic designations. However, all new entries will be recorded using UK Sanctions List Unique IDs.

Why this matters for firms

While the reform is intended to make sanctions compliance more straightforward, it will require firms to actively manage the transition.

Sanctions screening systems that currently rely on the OFSI Consolidated List will need to be updated. Firms will also need to ensure their governance frameworks accurately reflect the UK Sanctions List as the new standard, particularly where policies, procedures, or contractual obligations explicitly reference the Consolidated List.

For firms operating internationally, alignment across jurisdictions will be critical to avoid gaps, duplication, or conflicting controls.

Firms should take proactive steps to prepare.

Update screening data sources

  • Confirm that all sanctions screening systems are configured to use the UK Sanctions List.
  • Where systems rely on OFSI Group IDs, ensure they can accommodate UK Sanctions List Unique IDs for new designations.
  • Update internal policies, procedures, and compliance manuals to reflect the new framework.

Engage with screening providers

Where third-party screening tools are used, firms should confirm:

  • Whether the transition to the UK Sanctions List is already underway or complete
  • Whether any changes are required to ensure continuity of screening and alert management

Don’t assume third-party tools are already aligned. Confirm the data source switch, how alerts will be handled, and whether your screening logic needs to change.

Review contractual references

  • Identify contracts and supplier agreements that reference the OFSI Consolidated List.
  • Amend or future-proof language to ensure sanctions clauses clearly capture the UK Sanctions List going forward e.g. compliance with “all applicable UK sanctions lists.

How we can help

We support firms in navigating sanctions reform by:

  • Reviewing and adapting sanctions screening systems and controls
  • Updating compliance frameworks, policies, and procedure
  • Interpreting regulatory change across complex, multi-jurisdictional operations
  • Reviewing contracts and supplier arrangements for sanctions compliance obligations

We support firms in assessing and implementing sanctions-related regulatory change, including the transition to the UK Sanctions List.