Sanctions Explained
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UK sanctions explained

Last checked: 20 October 2026 · Measures explained

UK sanctions are made by ministers in regulations under the Sanctions and Anti-Money Laundering Act 2018 2. The Foreign, Commonwealth and Development Office (FCDO) sets sanctions policy, makes designations and publishes the UK Sanctions List 8. The Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, implements and enforces financial sanctions 7,8. Since 28 January 2026 the UK Sanctions List has been the only source for all UK sanctions designations 6. A designated person can ask the FCDO to revoke a designation and can go to court 4,5.
Main law
Sanctions and Anti-Money Laundering Act 2018 (SAMLA) 1
Power to make regulations in force
22 November 2018, under S.I. 2018/1213 2
Designations and policy
Foreign, Commonwealth and Development Office (FCDO) 8
Official list
UK Sanctions List, published by the FCDO 6
Financial sanctions body
OFSI, part of HM Treasury 7
Old OFSI list
Consolidated List of Asset Freeze Targets closed on 28 January 2026 6
Maximum civil penalty
The greater of £1,000,000 or 50% of the estimated value of the funds or resources, where the value can be estimated 9
Challenge route
Review request to the FCDO, then the High Court or the Court of Session 5,10

Legal basis under SAMLA 2018

Section 1 of the Sanctions and Anti-Money Laundering Act 2018 lets an appropriate Minister make sanctions regulations where the Minister considers it appropriate 2. The regulations can be made to comply with a UN obligation, to comply with any other international obligation, or for a purpose listed in section 1(2) 2. Section 1 came into force on 22 November 2018 2.

Each UK sanctions regime is a set of regulations made under the Act. The UK Sanctions List names the people, entities and ships designated or specified under those regulations 6.

  • Prevention of terrorism, in the UK or elsewhere 2.
  • National security, and international peace and security 2.
  • A foreign policy objective of the UK government 2.
  • Resolution of armed conflicts or protection of civilians in conflict zones 2.
  • Accountability for, or deterrence of, gross violations of human rights 2.
  • Compliance with international humanitarian law 2.
  • Multilateral efforts against weapons and materials of mass destruction 2.
  • Respect for democracy, the rule of law and good governance 2.

How a person is designated

Under section 11, a Minister may designate a person by name under the standard procedure only with reasonable grounds to suspect that the person is an "involved person" 3. That covers someone who took part in a specified activity, is owned or controlled by such a person, acts for such a person, or is a member of or associated with such a person 3. A designation needs a statement of reasons 3.

Section 11 has an urgent procedure. It applies where a comparable measure covers the person under the law of the US, the EU, Australia, Canada or another specified country, and the Minister considers urgent designation to be in the public interest 3. An urgent designation lapses after 56 days. It can continue only if the Minister certifies that the conditions are met 3. Section 13 of the Act deals with persons named by or under UN Security Council resolutions 1.

The UK Sanctions List

The FCDO publishes the UK Sanctions List. It lists designated or specified people, entities and ships and gives the reasons for each listing 6. The list was first published on 6 July 2020 and was last updated on 16 October 2026 6. It comes in several file formats and has a search tool 6.

On 13 October 2025 the FCDO said the OFSI list was closing 6. The OFSI Consolidated List of Asset Freeze Targets closed on 28 January 2026 and is no longer updated 6. From that date the UK Sanctions List is the only source for all UK sanctions designations 6.

Asset freezes and who must comply

OFSI guidance says UK sanctions apply to all persons within the territory and territorial sea of the UK 8. UK nationals and entities established in the UK, including their branches, must comply wherever they operate 8.

Under an asset freeze, a person may not deal with a designated person's funds or economic resources, or make them available to that person 8. The guidance says funds are frozen immediately and that a freeze does not transfer ownership or confiscate the assets 8. Relevant firms must tell OFSI as soon as practicable if they know or reasonably suspect that a person is designated or has breached a prohibition 8.

OFSI handles enquiries on asset freezes, issues general licences, decides licence applications, receives breach reports and publishes enforcement decisions 7.

Penalties

Under section 146 of the Policing and Crime Act 2017, the Treasury may impose a monetary penalty if it is satisfied on the balance of probabilities that a breach occurred 9. Since 15 June 2022, any requirement that the person knew, suspected or believed a matter is ignored when deciding if a breach occurred 9. That change was made by the Economic Crime (Transparency and Enforcement) Act 2022 9.

Challenging a designation

Under section 23 of the Act, a designated person may ask the Minister to vary or revoke a designation 4. After one request, a further request is allowed only if it raises a significant matter not considered before 4. The FCDO asks for a completed Sanctions Review Request Form sent to [email protected] 10. It says it is not possible to give exact timelines 10. Sanctions stay in place during the reassessment 8.

Under section 38, the person may apply to the High Court, or the Court of Session in Scotland, to set aside the decision 5. The court applies the principles of judicial review 5. A person on a UN list can ask the UK to use its best endeavours to secure removal from that list 10.

Common questions

Who decides UK sanctions designations?

The FCDO is responsible for UK sanctions policy, including designations, and publishes the UK Sanctions List 8.

What does OFSI do?

OFSI implements and enforces UK financial sanctions for HM Treasury. It issues licences, receives breach reports and publishes penalties 7,8.

Is the OFSI Consolidated List still used?

No. It closed on 28 January 2026 and is kept for reference only. The UK Sanctions List is now the single source of designations 6.

What is the maximum OFSI fine?

The greater of £1,000,000 or 50% of the estimated value of the funds or resources involved, where that value can be estimated. Otherwise the maximum is £1,000,000 9.

Can a UK designation be challenged?

Yes. A designated person can ask the FCDO to vary or revoke it, and can then apply to the High Court or the Court of Session 4,5 10.

Rules and fees change. Check the official site linked above before you apply or pay. Spotted an error? Email [email protected] with the official link.

Sources

  1. legislation.gov.uk: Sanctions and Anti-Money Laundering Act 2018, contents (accessed 20 October 2026)
  2. legislation.gov.uk: Sanctions and Anti-Money Laundering Act 2018, section 1, Power to make sanctions regulations
  3. legislation.gov.uk: Sanctions and Anti-Money Laundering Act 2018, section 11, Designation of a person by name
  4. legislation.gov.uk: Sanctions and Anti-Money Laundering Act 2018, section 23, Right to request variation or revocation of designation
  5. legislation.gov.uk: Sanctions and Anti-Money Laundering Act 2018, section 38, Court review of decisions
  6. GOV.UK, FCDO: The UK Sanctions List (updated 16 October 2026)
  7. GOV.UK: Office of Financial Sanctions Implementation, organisation page (accessed 20 October 2026)
  8. GOV.UK, OFSI: UK financial sanctions general guidance (updated 12 May 2026)
  9. legislation.gov.uk: Policing and Crime Act 2017, section 146, Power to impose monetary penalties
  10. GOV.UK, FCDO: Making a sanctions challenge, how to seek variation or revocation of a sanctions designation (updated 2 February 2023)

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