UK Sanctions Screening: OFSI & the HMT List Explained

UK sanctions screening is no longer just about matching a customer name against a database. Businesses must also identify aliases, ownership links, control relationships and indirect exposure to sanctioned parties.

The FCA has assessed the sanctions systems and controls of more than 150 financial services firms since February 2022, highlighting weaknesses in areas such as name screening, alert handling and due diligence. Strong screening processes are now a critical part of managing sanctions risk.

The terminology has also changed. The former ofsi list, often called the hmt sanctions list, closed in January 2026, with the UK Sanctions List becoming the current source for UK designations. This guide explains how the system works and what businesses need to check.

What Is OFSI?

The Office of Financial Sanctions Implementation (OFSI) is part of HM Treasury and plays a central role in UK sanctions screening and financial sanctions compliance. While businesses may still refer to the OFSI list or HMT sanctions list, OFSI is the authority responsible for implementing financial sanctions rather than the current source of UK designations.

Its responsibilities include:

• Financial sanctions compliance
• Reporting requirements
• Asset freezes
• Sanctions licences
• Ownership and control
• Potential sanctions breaches
• Enforcement and monetary penalties

OFSI guidance helps businesses understand who may be subject to sanctions, what activities are prohibited, and how reporting, licensing and enforcement requirements apply.

What Does OFSI Do?

OFSI turns UK financial sanctions rules into practical compliance requirements, making it an important part of UK sanctions screening.

Businesses rely on OFSI guidance when determining:

• Whether a customer is subject to financial sanctions
• Whether assets need to be frozen
• Whether funds can be made available
• Whether an incident must be reported
• Whether an OFSI licence is required
• Whether a company is owned or controlled by a sanctioned person

Although the historical OFSI list, also known as the HMT sanctions list, is no longer the current source for designations, OFSI remains central to how businesses interpret and comply with UK financial sanctions.

What Is the HMT Sanctions List?

The HMT sanctions list is a commonly used name for what was formally the OFSI Consolidated List of Asset Freeze Targets. It played an important role in UK sanctions screening by helping businesses identify individuals and entities subject to UK financial sanctions.

The list was widely used by banks, fintechs, regulated businesses and compliance teams. It is also commonly referred to as the OFSI list, HM Treasury sanctions list or OFSI Consolidated List.

You may still encounter several names for it, including:

• HMT List
• HM Treasury sanctions list
• OFSI list
• OFSI Consolidated List
• UK financial sanctions consolidated list

These terms largely refer to the former consolidated sanctions resource maintained by OFSI and HM Treasury.

Does the HMT Sanctions List Still Exist?

Not as a current sanctions source.

The HMT sanctions list, formally the OFSI Consolidated List, closed on 28 January 2026 and is no longer updated. Businesses carrying out UK sanctions screening should now use the UK Sanctions List as the current source for UK sanctions designations.

The historical OFSI list may still be accessible for reference, but it only reflects designations made up to its closure date. It should therefore not be relied upon for current sanctions checks.

HMT List vs UK Sanctions List

Why Did the UK Move Away From the OFSI List?

Previously, compliance teams carrying out UK sanctions screening could encounter information across both the UK Sanctions List and the OFSI list.

From 28 January 2026, the government simplified this structure by making the UK Sanctions List the sole source for current UK sanctions designations. This means screening systems, compliance policies and internal procedures should no longer depend on the historical HMT sanctions list.

For businesses, the practical takeaway is clear: the OFSI list and HMT sanctions list remain useful historical terms, but current UK sanctions screening should rely on the UK Sanctions List.

How Does OFSI Fit Into UK Sanctions Screening?

A strong sanctions screening process should not stop at finding a name on a list.

Businesses need to determine whether the alert represents the same person or entity and whether sanctions restrictions apply.

Collect Customer Information

Effective UK sanctions screening starts with accurate customer data. Collect full names, dates of birth, addresses, nationality, identification details and relevant company information before running sanctions checks.

For businesses, also capture directors, shareholders and beneficial owners. Complete information makes it easier to distinguish a genuine sanctions match from someone who simply has a similar name.

Screen Against the UK Sanctions List

Screen individuals and entities against the current UK Sanctions List. Do not rely on the historical OFSI list or HMT sanctions list, as these terms refer to the former consolidated sanctions resource.

Screening should consider more than exact names. Aliases, alternative spellings and other identifying details can reveal potential sanctions exposure that a basic name search may miss.

Investigate Potential Matches

A sanctions alert should trigger further investigation, not an automatic decision. Compare the customer's name, date of birth, nationality, address and other identifiers with the information available for the designated person.

This is a key part of UK sanctions screening because similar names can create false positives. Strong alert investigation helps businesses separate genuine matches from unrelated customers without overlooking real sanctions risks.

Check Ownership and Control

A company does not always need to appear directly on a sanctions list to be affected. Businesses should check whether a designated person owns or controls the company through shares, voting rights or other forms of influence.

This makes ownership data especially important when screening companies. Looking beyond the OFSI list or historical HMT sanctions list helps identify indirect sanctions exposure hidden within corporate structures.

Apply OFSI Requirements

If a potential match is confirmed, assess which OFSI requirements apply. Depending on the sanctions regime and circumstances, this may involve freezing funds, stopping prohibited activity, reporting information or seeking an appropriate licence.

Businesses should document how the decision was reached and escalate higher-risk cases internally. OFSI guidance should form part of the compliance framework supporting UK sanctions screening and sanctions-related decisions.

Maintain Ongoing Monitoring

Sanctions status can change after onboarding, so screening should not be treated as a one-time check. Customers, companies and connected parties should be rescreened when sanctions lists or relevant customer information changes.

Ongoing monitoring also helps businesses move away from outdated reliance on the OFSI list or HMT sanctions list. Current UK sanctions screening should use updated designation data and trigger reviews when new risks emerge.

Why Ownership and Control Matter

Ownership and control can turn an apparently clear company into a sanctions risk. Effective UK sanctions screening should therefore look beyond a direct name match and examine shareholders, beneficial owners and controlling relationships, because an entity may still be affected if a designated person owns or controls it. This is why relying only on the historical OFSI list or HMT sanctions list can miss indirect exposure hidden within corporate structures.

What Happens If You Find a Sanctions Match?

A sanctions alert is the start of an investigation, not an automatic finding. During UK sanctions screening, businesses should compare names, dates of birth, addresses, nationality and other identifiers to determine whether the result is a false positive, possible match or genuine target match. 

If sanctions exposure is confirmed, OFSI requirements may involve freezing assets, stopping prohibited activity, reporting the case or seeking a licence, while the old OFSI list and HMT sanctions list should not be used as current designation sources.

Common Mistakes When Using the HMT List

Effective UK sanctions screening depends on current data, accurate customer information and consistent monitoring. 

Businesses can create serious compliance gaps when they rely on outdated lists or treat sanctions checks as a simple name-matching exercise.

Common mistakes include:

Screening only against the old HMT sanctions list - The HMT sanctions list is no longer the current source for UK designations. Using it alone can leave businesses exposed to newer sanctions that appear only on the UK Sanctions List.

Treating the historical OFSI list as a current source - The former OFSI list is useful for historical reference, but it should not drive current screening decisions. Modern UK sanctions screening should use the UK Sanctions List as the active source.

Ignoring aliases and identity information - A person may appear under a different spelling, alias or transliteration. Comparing dates of birth, nationality, addresses and identification details helps distinguish true matches from false positives.

Treating onboarding screening as a one-time check - A customer who is clear today could become sanctioned later. Ongoing monitoring helps businesses detect new designations and changes in sanctions exposure throughout the relationship.

Failing to update sanctions data promptly - Delayed list updates can create a window where newly designated individuals or entities remain undetected. Screening systems should use current sanctions data and refresh quickly when designations change.

Assuming a company is clear because its name is absent from the list - A company may still be affected if it is owned or controlled by a designated person. Effective UK sanctions screening should therefore examine ownership and control, not just whether the company appears directly on a sanctions list.

Bottom Line

The UK sanctions framework has changed, but the compliance objective remains the same: identify sanctions exposure quickly and act on it correctly. The historical OFSI list and HMT sanctions list are no longer current screening sources, while OFSI continues to shape how businesses interpret, report and manage financial sanctions obligations.

Effective UK sanctions screening now depends on using the current UK Sanctions List, verifying potential matches carefully, checking ownership and control, and monitoring customers over time. Businesses that combine current sanctions data with strong identity and ownership checks are better placed to detect both direct and hidden sanctions risk.

FAQs About OFSI & the HMT List