Financial sanctions are restrictions imposed by the government on dealing with certain people, entities or regimes. Where anti-money-laundering rules ask you to manage risk proportionately, sanctions are far blunter: if a target is designated, you generally cannot deal with their funds or economic resources at all. A breach is a serious matter — and, as this guide explains, you can now be penalised for one even if you did not know you were breaching.
This is the complete picture: the legal framework, the single list you must screen against in 2026, what an asset freeze actually prohibits, how sanctions reach companies that designated people own or control, and the strict-liability penalty regime that makes screening non-negotiable.
The legal framework
Since the UK left the EU, its autonomous sanctions regime rests on the Sanctions and Anti-Money Laundering Act 2018 (SAMLA). SAMLA gives ministers the power to make sanctions regulations — by country (such as Russia, Iran or Myanmar) or by theme (such as global anti-corruption or counter-terrorism). Individual people, entities and ships are then designated under those regulations.
Two government bodies share the work:
| Body | Role |
|---|---|
| FCDO (Foreign, Commonwealth & Development Office) | Decides who is designated; maintains the official UK Sanctions List |
| OFSI (Office of Financial Sanctions Implementation, HM Treasury) | Implements and enforces financial sanctions; issues guidance and licences; imposes penalties |
The single UK Sanctions List
This is the part most likely to trip up anyone relying on older information.
According to GOV.UK, the UK Sanctions List — maintained by the FCDO under SAMLA — is now the single, authoritative source against which UK sanctions screening should be conducted. It is published in searchable form and as downloadable files (PDF, CSV, XML and others). Updating your process to screen against it is essential.
What an asset freeze means
The most common financial-sanctions measure is an asset freeze. When a person or entity is subject to one, you must not:
- Deal with their funds or economic resourcesProhibited
- Make funds or economic resources available to them or for their benefitProhibited
- Do so directly OR indirectlyBoth prohibited
- Unless a licence or exception permits itThe only way through
"Economic resources" is broad — it covers assets of every kind, not just cash. Two features make asset freezes unusually strict:
- Immediate. They take effect the moment of designation, not after a grace period.
- No de minimis. There is no "small enough to ignore" amount.
Strict liability and penalties
OFSI can impose civil monetary penalties for breaches, and the standard changed significantly. Since 15 June 2022, OFSI has been able to impose penalties on a strict-liability basis.
OFSI's enforcement and monetary penalties guidance explains how it assesses cases.
OFSI weighs the offender's actual and expected knowledge given the nature of their business and exposure to sanctions risk — so being in a high-risk sector raises the bar for what counts as reasonable. Serious breaches can also be prosecuted criminally. The combination of strict-liability civil penalties and potential criminal exposure is why sanctions screening is treated as non-negotiable, not best-effort.
Sanctions vs PEP vs adverse media
People often blur three different checks together. Being precise matters, because they have different legal consequences.
Three screening checks, three very different consequences. Match each.
For the full comparison, see sanctions vs PEP vs adverse media.
What to do when a name matches
A potential sanctions match is one of the few moments in compliance with a near-fixed sequence. Put these in the right order.
A screen flags a possible match against the UK Sanctions List. What happens, in order?
- Document the decision and the evidence behind it
- Report to OFSI: if a designated person is involved, comply with the reporting obligation
- Freeze: do not proceed with the transaction or make funds/resources available
- Check ownership/control: consider whether unnamed entities are caught via a designated owner
- Confirm identity: check the match is really your subject, not a namesake (name, DOB, identifiers)
- Apply for a licence if a legitimate dealing needs to proceed lawfully
Screening in practice
A Probitas screen checks a name against the UK Sanctions List alongside major international sanctions sources, PEP data and adverse media — and, because sanctions can reach owned-and-controlled entities, it does so with an eye to the ownership structures revealed in the public record. A sanctions match is treated as exactly what the law says it is: a stop, not a score.
UK
What is the difference between sanctions and anti-money-laundering rules?
AML rules ask you to assess and manage risk proportionately — you can still do business with higher-risk customers if you apply enhanced due diligence. Sanctions are a prohibition: if a target is designated, you generally cannot deal with their funds or economic resources at all, regardless of risk appetite.
Which list should I screen against in 2026?
The UK Sanctions List, maintained by the FCDO under SAMLA. Since 28 January 2026 it is the single authoritative source. The old OFSI Consolidated List has closed and is no longer updated — screening against it means missing every designation made since.
What does "strict liability" mean for sanctions penalties?
Since 15 June 2022, OFSI can impose a civil monetary penalty without proving you knew or suspected you were breaching. The breach itself can be enough. Your knowledge still affects how OFSI assesses the case, but lack of intent is not an automatic defence.
Do sanctions apply to companies that aren't named on the list?
Yes. An asset freeze can reach an entity that a designated person owns or controls — typically a holding over 50% or the ability to control — even if that entity is not itself named. This is why screening must consider ownership and control, not just the names on the list.
Is there a minimum amount below which sanctions don't apply?
No. There is no de minimis threshold for an asset freeze. No transaction is "small enough to ignore," and the freeze takes effect immediately on designation.
What should I do if a customer matches a sanctions designation?
Do not proceed with the dealing. Confirm the match is really your subject (not a namesake), consider ownership and control, comply with the obligation to report to OFSI where a designated person is involved, apply for a licence if a legitimate dealing must proceed, and document everything. Freeze first, verify second.
Sources
This guide is written from primary sources. Each is linked below; claims in the text link to the specific reference they rely on.