Category: Compliance & AML · Reviewed by Al Jabbar, Broker · Specialist Risks · Last reviewed June 2026
The three principal published lists of persons, entities and bodies subject to financial sanctions — the UN Security Council Consolidated Sanctions List, the EU Consolidated Sanctions List, and the UK Sanctions List maintained by OFSI.
The consolidated sanctions lists are the published registers of designated persons and entities subject to financial sanctions in the UN, EU and UK regimes respectively. For a UK firm, the operative list is the UK Sanctions List maintained by OFSI. The UN list is incorporated into UK law by the relevant SAMLA-based regulations. The EU list applies in the UK only to the extent retained or independently implemented post-Brexit.
The UK Sanctions List is maintained under the Sanctions and Anti-Money Laundering Act 2018 and the specific country-thematic regulations. The UN Consolidated List is maintained by the UN Security Council Sanctions Committees under UN Security Council Resolutions. The EU Consolidated Sanctions List is maintained under the Common Foreign and Security Policy with implementing regulations under article 215 TFEU.
A regulated firm screens its customers, beneficial owners, payees and counterparties against the UK list at onboarding and on each transaction. Many firms also screen against the UN and EU lists for completeness — particularly where cross-border activity is involved. Screening is typically automated against a commercial provider’s consolidated database, with manual review of potential matches. Confirmed matches require freezing, reporting to OFSI, and consideration of licence applications.
Designations may attach not only to named individuals and entities but also to entities owned or controlled by designated persons (the so-called “50% rule” — though the UK applies a control-and-ownership test that does not depend solely on a 50% threshold). Sectoral sanctions (e.g. ban on certain trade with specified Russian entities) operate on activity type, not just designation.
Apex’s onboarding screen identifies a potential match between a customer’s named director and the UK Sanctions List. The compliance team reviews the match against full name, date of birth and other identifiers. Where the match is confirmed, the firm freezes related premium funds, reports to OFSI within the required timeframe, and considers whether a licence application is needed before paying claims or continuing service.
UK Sanctions List (OFSI). UN Security Council Consolidated Sanctions List. EU Consolidated Sanctions List (subject to UK retention post-Brexit). Sanctions and Anti-Money Laundering Act 2018. United Nations Act 1946 (historical basis for UN sanctions implementation in UK).
By Matt Bartlett, Director, on 2026-06-11.
This entry is part of the Apex Insurance Wiki. Last reviewed by Matt Bartlett on 2026-06-11. Apex Insurance Brokers Limited, FCA FRN 724952, Companies House 07014570. Not regulated advice — consult your broker on your specific position.
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