What is the UK HMT list,
and how does OFSI screening work?
Since Brexit, the UK runs its own autonomous sanctions regime, and it has quietly diverged from both the EU and US lists it once mirrored. This guide covers how HM Treasury and OFSI administer UK sanctions, and how screening against them works in practice.
6 min read · Sanctions screening basics
What the UK sanctions regime actually is
His Majesty's Treasury, HMT, oversees UK financial sanctions through the Office of Financial Sanctions Implementation, universally referred to as OFSI. Since the UK left the EU, sanctions are no longer implemented through EU regulations directly; they run under the UK's own Sanctions and Anti-Money Laundering Act 2018, generally shortened to SAMLA, which gives the UK government authority to create autonomous sanctions regimes by statutory instrument.
OFSI maintains the UK Sanctions List, covering financial sanctions: asset freezes and restrictions on making funds available to designated persons. Trade sanctions, export bans, and related restrictions on goods and services sit alongside this, overseen in part by the Office of Trade Sanctions Implementation, a separate but related function.
Why the UK list is not just a copy of the EU list
In the years immediately after Brexit, the UK list largely mirrored its EU counterpart, since it was built from the same starting designations. That has changed. The UK now runs its own designation and delisting process, and new listings, along with new trade restrictions, are added on the UK's own timeline. A party removed from the EU list is not automatically removed from the UK list, and vice versa.
- Dealing with a designated person's funds or economic resources without a license is a criminal offense under UK law.
- OFSI operates on a similar strict liability basis to OFAC: a breach does not require intent to be enforceable.
- General licenses issued by OFSI can permit specific categories of activity that would otherwise be prohibited, but only within their stated conditions.
- Penalties include significant civil monetary penalties and, for serious breaches, criminal prosecution.
Who and what is designated
Like the EU and US, the UK runs both country-specific regimes and thematic regimes. Country regimes have been particularly active around Russia and Belarus in recent years; thematic regimes cover terrorism, cyber activity, human rights abuses, and chemical weapons, among others.
Each listing on the UK Sanctions List carries a unique reference number, and where a person appears under multiple aliases or related entries, OFSI groups them under a shared group identifier. This structure is a useful signal during screening: a match on the group ID can surface related entities that a plain name search would miss.
How UK sanctions screening works in practice
Screening against the OFSI Consolidated List follows the same basic principles as any other list: fuzzy name matching, secondary identifiers where available, and ongoing re-checks rather than a single point-in-time review. What differs is that a program built only around the EU or US lists will not automatically catch UK-specific designations, and needs its own dedicated check against the UK list.
Trade sanctions add a second layer beyond financial screening. Even where a counterparty is not personally designated, specific goods, technologies, or services may be restricted by category under UK trade sanctions regulations, which requires monitoring the underlying statutory instruments rather than relying on name screening alone.
Common mistakes
Assuming UK and EU lists still match post-Brexit
The two regimes have diverged meaningfully since 2020. A clean EU check is not a substitute for a UK check.
Missing UK-specific trade sanctions
Category-based export or service restrictions apply independent of any named party and are easy to overlook if screening is limited to the Consolidated List.
Not checking general license conditions before relying on one
A general license permits activity only within its specific scope. Assuming broader coverage than what is actually written is a common and costly error.
Getting started
- Screen the UK Sanctions List separately from the EU and US lists, rather than assuming overlap.
- Use group ID references when available to catch related aliases and entities in a single match.
- Monitor UK trade sanctions instruments alongside financial sanctions screening.
- Read any general license in full before relying on it for a specific transaction.
UK sanctions have become their own regime in practice, not a smaller mirror of the EU's. Treating it that way in screening is what closes the gap.
See the UK list screened
alongside the rest of the world.
Enthron screens against the OFSI Consolidated List and keeps pace with UK-specific designations that have no direct EU or US equivalent.