Changes to UK sanctions designations list: What African operations need to know
The UK Sanctions List (published by the Foreign, Commonwealth and Development Office) will become the sole official register of UK sanctions designations, and the current Consolidated List of Asset Freeze Targets (published for HM Treasury by OFSI and also referred to as the Consolidated List of Financial Sanctions Targets) will be retired on that date.
UK sanctions do not automatically bind non-UK entities. However, due to the number of UK-headquartered banks and investors operating across Africa, and mindful that many African financings are London-led or reference English law, this change is likely to impact many banks, financial institutions and other organisations conducting sanctions screenings on the continent.
Why is this change happening?
There are currently two separate UK sanctions-related lists which include overlapping, but not identical, data:
- The UK Sanctions List is the official record of all designations and measures created under UK law.
- The OFSI Consolidated List is designed for financial institutions and businesses and consolidates all persons and entities subject to financial sanctions under both the UK regime and the UN regimes implemented in the UK.
Therefore, the move to a single, authoritative list is in response to industry feedback that such an approach will remove duplication of effort and simplify sanctions checks.
Impact on finance documentation
Many finance documents, such as credit agreements and facility letters, define ‘Sanctions’ or ‘Sanctions List’ by referencing, amongst others, the OFSI Consolidated List. Similarly, the HM Treasury is often defined as a ‘Sanctions Authority’.
From 28 January 2026, these references will be outdated, unless the definitions include catch-all or successor language. Lenders should update sanctions related definitions to refer to the UK Sanctions List and ensure related provisions remain accurate.
It is expected that the LMA will publish an update on this transition in due course. In the interim, for legacy transactions without appropriate catch-all or successor language, lenders may consider using administrative amendments to update definitions without seeking full consent, where permitted.
If a legacy agreement requires consent to administrative changes, the lender should consider a targeted consent campaign for high-priority facilities (eg. deals with UK parties or sterling clearing, deals in imbalanced risk positions, and high-value or long-dated facilities). For new transactions, parties should adopt forward compatible drafting.
Interaction with AML obligations
The transition to a single list does not alter the underlying AML legal framework or the obligation to maintain effective customer due diligence, including ongoing monitoring and screening. However, impacted organisations must ensure their AML controls continue to identify persons subject to UK financial sanctions by sourcing data from the UK Sanctions List.
Policies, enterprise wide risk assessments, KYC procedures, PEP/ sanctions screening standards, customer and payment screening rules and record keeping policies should therefore be updated to reflect the new data source.
Where organisations use third party screening providers, automated screening tools and/ or monitoring platforms, they should ensure the vendors, tools and/ or platforms will transition in time and update any service terms and audit rights to reflect the UK Sanctions List as the authoritative UK source.
Implications for international trade and cross border activity
Organisations with cross border activities must continue screening against other relevant regimes (eg. UN, EU, US) and manage conflicts of law and extraterritorial risks.
Trade and supply-chain finance documentation should be reviewed to ensure UK sanctions references point to the UK Sanctions List from the transition date.
Operationally, organisations should align cut over plans across sanctions, AML, trade finance and payments so that screening, list refreshes and name matching are synchronised with the changeover.
Next steps
To prepare for 28 January 2026, impacted organisations should:
- Reconfigure systems and procedures (including any vendor screening tools) to source data from the UK Sanctions List.
- Update all policies, templates and live finance documents to replace references to the OFSI Consolidated List with the UK Sanctions List.
- Confirm with third-party providers that the UK Sanctions List will be recognised as the authoritative source from 28 January 2026 and complete all necessary testing before the changeover.
- Update template finance documents and consider administrative amendments for legacy deals to ensure enforceability post-transition.
The UK’s move to a single sanctions list is largely technical, but failure to prepare may create commercial and legal friction, giving rise to disputes over which list governs contractual prohibitions, representations or termination rights.
Organisations with any UK nexus should treat the switch as a core compliance project and take steps to map exposure, secure vendor assurance, update definitions and templates, and test end-to-end before the transition date.
An official Government announcement (available here) provides further details.