Later this month (28 January), the government is changing how information on sanctions is being kept and stored.
The new approach means that there will be a single source for businesses checking sanctions information.
“Most small businesses will see little or no day-to-day impact”, says Andy Bridges, a sanctions and export controls expert at the Chartered Institute of Export & International Trade.
“However, if you occasionally check customers, suppliers or overseas payments against UK sanctions (for example, when trading internationally), you should make sure you are using the UK Sanctions List going forward.
“This change is mainly about using the correct government list and should not add any new requirements for SMEs.”
What is happening?
At 9am on 28 January, the government is moving to a single list for UK sanctions designation.
Up until now, the government has used two lists:
- The UK Sanctions List (UKSL), published by the Foreign, Commonwealth and Development Office (FCDO)
- The Consolidated List of Asset Freeze Targets, published by the Treasury and the Office of Financial Sanctions Implementation (OFSI)
On 28 January, the UKSL will be the only sanctions list which is updated. The OFSI’s own Consolidated List will no longer be updated, says the government, which is now pushing traders to prepare for the switch to the single-source UKSL.
What do I need to do as part of the switch?
The government is urging companies to switch over to the UKSL as soon as possible. All screening systems using the OFSI Consolidated List as a basis should switch to UKSL instead.
There will be a change to how newly designated persons (DPs) subject to financial sanctions are identified.
All systems using the ‘OFSI Group ID’ should switch to ‘Unique ID’ as identifier for new designations. As part of this:
- Any external systems that use ‘OFSI Group ID’ to identify DPs subject to financial sanctions will need to be updated to use the UK Sanctions List ‘Unique ID’ and ‘Sanction Type’ fields instead.
- Currently all DPs and specified ships are given a ‘Unique ID’. Those DPs subject to financial sanctions are also given an ‘OFSI Group ID’.
More recommended steps include speaking to any third-party software providers to understand how this might impact the data that traders receive and using the time before 28 January to prepare any systems for the closure of the OFSI consolidated list.
The government says that those already signed up to e-alerts about changes to designations will continue to receive these and will not need to resubscribe.
What does this mean for me?
The government describes the UKSL as the “single, authoritative source for all UK sanctions designations.”
The search function has been active since January 2024, and allows users to look for information on any designated persons under sanctions law in the UK.
The UKSL is already live for businesses to use. No new information or data is planned to be included in the UKSL as part of the changes, and no new changes are being made to the formatting of existing file types.
The government says the UKSL’s search function is getting an upgrade this month, with tools like ranked results, highlighted matches, and improved downloads.
A format and user guide is set to be published on 28 January.