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 explained below — you can now be penalised for one even if you did not know you were breaching.
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:
- The Foreign, Commonwealth & Development Office (FCDO) decides who is designated and maintains the official list.
- The Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, implements and enforces financial sanctions, issues guidance and licences, and imposes penalties.
The single UK Sanctions List
This is the part most likely to trip up anyone relying on older information. As of 28 January 2026, the UK Sanctions List is the only source for UK sanctions designations.
Previously, those screening for financial sanctions used OFSI's "Consolidated List of Asset Freeze Targets". That list closed on 28 January 2026 and is no longer updated. 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).
If your screening process still points at the old OFSI Consolidated List, it is pointing at a list that no longer moves. Updating to the UK Sanctions List 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 an asset freeze, you must not:
- deal with their funds or economic resources; or
- make funds or economic resources available to them, or for their benefit,
directly or indirectly, unless a licence or exception permits it. "Economic resources" is broad — it covers assets of every kind, not just cash. Asset freezes take effect immediately on designation, and there is no de minimis: there is no "small enough to ignore" amount.
Importantly, asset freezes can reach entities that a designated person owns or controls, even if that entity is not itself named. This is why sanctions screening cannot stop at the named individual — you have to understand ownership and control, which is where beneficial-ownership analysis becomes part of sanctions compliance.
Strict liability and penalties
OFSI can impose civil monetary penalties for breaches of financial sanctions, and the standard for doing so changed significantly. Since 15 June 2022, OFSI has been able to impose penalties on a strict-liability basis. In plain terms: OFSI no longer has to prove that you knew, suspected or had reasonable cause to suspect you were breaching sanctions. The breach itself can be enough.
OFSI's enforcement and monetary penalties guidance explains how it assesses cases. The statutory maximum penalty has been the higher of £1 million or 50% of the value of the breach — and the government has indicated an intention to increase this further (to the higher of £2 million or 100% of the breach value) when parliamentary time allows. OFSI weighs the offender's actual and expected knowledge given the nature of their business and their 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 are different from AML — and from PEP screening
It is worth being precise about three things people often blur together:
- Sanctions screening asks: is this person or entity (or an entity they own or control) designated? If yes, you generally cannot deal with them.
- PEP screening asks: is this person politically exposed, and therefore higher-risk? If yes, you apply enhanced due diligence — but you can still do business.
- Adverse-media screening asks: is there credible negative information about this person? It informs risk; it is not a legal prohibition.
A sanctions hit is a hard stop. The other two inform a judgement.
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.
Sources
This guide is written from primary sources. Each is linked below; claims in the text link to the specific reference they rely on.