Financial sanctions checks and reporting to OFSI

Which list to check

The UK moved to a single list for sanctions designations on 28 January 2026. Designations now appear in the UK Sanctions List, and the OFSI Consolidated List of Asset Freeze Targets is no longer updated. See the government's announcement.

Your reporting duty

OFSI's general guidance says relevant firms must inform OFSI as soon as practicable if they know, or have reasonable cause to suspect, that a person is a designated person or has breached financial sanctions, where the information came to them in the course of their business. Accountancy and tax firms can fall within the definition of a relevant firm, so check the full definition in OFSI's guidance.

If the designated person is your client, the guidance says your report must also state the nature and amount or quantity of any funds or economic resources you hold for them.

Dealing with a possible match

• Compare the details on the list, such as date of birth and nationality, with what you know about your client.
• Don't act for the client, or deal with their funds, while you check.
• If you conclude it is a genuine match, report it to OFSI and speak to your MLRO.

Sanctions and suspicious activity reports

A report to OFSI is a sanctions obligation. Separately, your MLRO should consider whether a suspicious activity report to the National Crime Agency is also needed.