What is the difference between the UK, UN, EU and US sanctions lists?

Four lists matter to a UK firm, and only one of them is UK law.

UK Sanctions List. Published by the Foreign, Commonwealth and Development Office (FCDO). Since 28 January 2026 it is the single list of everyone designated under UK sanctions: OFSI's separate Consolidated List closed on that date. OFSI (the Office of Financial Sanctions Implementation, part of HM Treasury) still implements and enforces financial sanctions, and it is who you report to. If a person or company is on the UK list, dealing with their funds, or making funds or economic resources available to them, is prohibited without a licence. Every UK business is bound by it, whatever its size or sector.

UN Security Council Consolidated List. Designations under Security Council resolutions (terrorism, Iran, North Korea and others). The UK gives effect to them in UK law, so UN designations also appear on the UK list. Screening the UN list directly covers any gap before the UK list is updated.

EU Consolidated Financial Sanctions List. Binds the EU and EU businesses. Since Brexit it doesn't bind a UK firm directly, and it differs from the UK list, but it matters if you deal with EU counterparties, EU property or EU banks, and many UK firms screen it as good practice.

US OFAC lists (SDN and others). Bind US persons and US dollar payments, and the US can penalise non-US firms that help sanctioned people evade them. Relevant if any party, payment or bank has a US link.

Certaby screens all four in one check, refreshed daily from the government sources, and records on the certificate which lists were screened and the date of each version.

Source: FCDO: The UK Sanctions List

Last updated 2 October 2026.