From Wednesday, 28 January 2026, the UK Sanctions List (“UKSL”), published by the Foreign, Commonwealth and Development Office, will act as the sole source of UK sanctions designations made under the Sanctions and Anti-Money Laundering Act 2018 (“SAMLA”). OFSI’s Consolidated List of Asset Freeze Targets (the “OFSI List”) and its search tool will not be updated beyond 28 January 2026.

The move to a single sanctions list is intended to simplify how businesses and individuals subject to sanction designations are identified, without altering sanctions scope or business obligations under UK law. The format of the UKSL will remain unchanged. This transition is a direct result of industry feedback received during a 2025 cross-government review, with an emphasis on removing the need to cross-reference multiple sources in hopes of reducing the risk of non-compliance.

Businesses should ensure that any internal systems which draw on the data from the OFSI List now draw from the UKSL. The UKSL will continue to be updated, and will be available in seven data formats.

In addition to these changes, any newly designated persons (DPs) subject to financial sanctions will no longer be assigned an OFSI Group ID; instead they will only have a Unique ID as an identifier. All UKSL formats will retain the historic OFSI Group ID data, meaning any historic Group IDs will continue to be valid for use.

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Photo of Sophie Davis Sophie Davis

Sophie Davis is an associate in Crowell’s London office and advises clients on a range of sanctions, export controls, and trade compliance matters. Sophie has particular experience advising multinational corporations and financial institutions on how to comply with rapidly evolving trade and financial

Sophie Davis is an associate in Crowell’s London office and advises clients on a range of sanctions, export controls, and trade compliance matters. Sophie has particular experience advising multinational corporations and financial institutions on how to comply with rapidly evolving trade and financial sanctions across a range of EU and UK sanctions regimes, assisting corporate clients with complex sanctions issues arising from their continued operations in, or divestments from, Russia, and supporting clients with licensing applications and responding to investigations.

Sophie also assists companies on compliance with anti-bribery and anti-money laundering laws, foreign direct investment requirements, human rights, environmental and sustainability regulatory requirements. Prior to joining Crowell & Moring, Sophie worked in the international trade and regulatory team in another top international law firm, based in London, as well as for a leading New Zealand law firm.