UK Sanctions List

Since Brexit, the United Kingdom maintains its own independent sanctions regime under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA), separate from the EU. The Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, administers financial sanctions and can impose monetary penalties on a strict liability basis — meaning no intent or knowledge is required for a breach.

The post-Brexit UK sanctions framework

Before Brexit, the UK implemented EU sanctions directly. Since the transition period ended on 31 December 2020, the UK has operated its own independent sanctions regime under SAMLA. This means:

• The UK can designate parties independently of the EU — and does
• The UK maintains its own sanctions list, separate from the EU Consolidated Financial Sanctions list
• There is significant overlap, particularly on Russia sanctions, but the lists are not identical
• Organisations operating in both the UK and EU must screen against both lists

In January 2026, the UK moved to a single consolidated list format for all UK sanctions designations, simplifying the previously fragmented structure.[1]

OFSI: enforcement and monetary penalties

OFSI is responsible for civil enforcement of UK financial sanctions. Since June 2022, OFSI has had the power to impose monetary penalties on a strict liability basis — the same standard used by OFAC in the United States.[2]

The maximum civil penalty is the greater of £1 million or 50% of the estimated value of the breach. Criminal sanctions for wilful violations can result in imprisonment.

What UK sanctions cover

UK sanctions measures vary by regime but can include:

• Asset freezes — all funds and economic resources owned, held, or controlled by designated persons must be frozen
• Financial restrictions — prohibitions on providing financial services, making funds available, or engaging in financial transactions with designated persons
• Trade sanctions — restrictions on import and export of specified goods (arms, luxury goods, oil, technology)
• Transport sanctions — restrictions on ships, aircraft, and maritime services
• Immigration sanctions — travel bans preventing designated persons from entering the UK

Since Russia's invasion of Ukraine, the UK has implemented extensive sanctions on Russia, including the Russian oil price cap, restrictions on maritime services for Russian oil transport, and a designated person asset reporting requirement unique to the Russia and Belarus regulations.[2]

Who must comply

• All UK persons — individuals who are British citizens, or are in the UK
• All UK entities — bodies incorporated or constituted under UK law, including overseas branches
• Anyone conducting activities within the UK — regardless of nationality

In practice, any organisation with UK operations, UK clients, or transactions touching the UK financial system should screen against the UK sanctions list.

UK vs EU vs OFAC: why all three matter

Since Brexit, the UK, EU, and US each maintain separate sanctions regimes. While there is substantial overlap — particularly on Russia, Iran, and North Korea — there are meaningful differences:

• The UK may designate parties the EU has not, and vice versa
• The scope of restrictions can differ even for parties listed by all three
• Licence requirements and exemptions vary across jurisdictions
• Organisations with cross-border operations may need to comply with all three simultaneously