On October 13, 2025, the Foreign, Commonwealth & Development Office (“FCDO”), the Office of Financial Sanctions Implementation (“OFSI”) and His Majesty’s Treasury (“HM Treasury”) confirmed that from January 28, 2026, the UK Sanctions List (“UKSL”) will be the single official source of United Kingdom (UK) sanctions designations. The OFSI Consolidated List will close. The change follows a cross-government review and industry feedback to simplify screening.

Who Is Affected?

  • All Firms conducting sanctions screening (banks, asset managers, insurers, professional services, marketplaces, FinTechs, crypto, trade/commodity firms) and any third-party screening vendors that source UK designations.
  • Non-UK businesses operating outside the UK but screening for UK exposure should also align their sources and controls.

Why It Matters

A single list should cut duplication, reduce false negatives from mismatched fields, and streamline vendor integrations. Guidance has been published to help firms prepare; the UK Government recommends switching to UKSL as the primary data source now (and in any case before January 28, 2026).

What Firms Should Do Now

Firms should update policies to cite the UK Sanctions List as the authoritative source from go-live and brief teams while ensuring subscriptions to Foreign, Commonwealth & Development Office/Office of Financial Sanctions Implementation update alerts remain active.

For further information please contact ukreg@proskauer.com.  

Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of John Verwey John Verwey

John Verwey is a Regulatory partner and a member of the Firm’s Private Capital industry group.

John advises on financial services regulatory matters at a national UK and European level. He specializes in advising investment firms, including venture, private equity, credit, and hedge…

John Verwey is a Regulatory partner and a member of the Firm’s Private Capital industry group.

John advises on financial services regulatory matters at a national UK and European level. He specializes in advising investment firms, including venture, private equity, credit, and hedge fund managers as well as institutional managers and advisers, on all aspects of the UK and EU regulatory regimes.

Another key area of focus is advising clients in the financial services sector on mergers and acquisitions, re-organisations and associated regulatory approvals.

John represents a variety of clients that range from small start-up fund managers to established global fund advisers and managers. In The Legal 500, John is noted as “an all-rounder who gets into the details and manages client expectations on navigating tricky regulatory requirements”.

Photo of Anna Maleva-Otto Anna Maleva-Otto

Anna Maleva-­Otto is a Regulatory partner and a member of the Firm’s Private Capital industry group.

Anna advises on a range of UK financial services regulatory matters, including the impact of EU directives and regulations, the establishment and operation of FCA-­regulated businesses in…

Anna Maleva-­Otto is a Regulatory partner and a member of the Firm’s Private Capital industry group.

Anna advises on a range of UK financial services regulatory matters, including the impact of EU directives and regulations, the establishment and operation of FCA-­regulated businesses in the UK, as well as trading on UK and EU markets.

Anna also often assists clients with the design of their compliance policies and procedures, internal investigations and staff training. She frequently participates in industry working groups in connection with new and emerging regulatory initiatives and has advised asset managers on several key pieces of recent EU legislation, including General Data Protection Regulation (GDPR), Short Selling Regulation, Alternative Investment Fund Managers Directive (AIFMD), the second Markets in Financial Instruments Directive (MiFID II), Market Abuse Regulation (MAR), the Securities Financing Transactions Regulation (SFTR), European Market Infrastructure Regulation (EMIR) and Securitization Regulation.

Anna has been named among the world’s 50 Leading Women in Hedge Funds by The Hedge Fund Journal and frequently speaks and writes on topics related to her areas of experience. She has previously co-authored the UK chapter in the Chambers Alternative Funds Guide – a guide examining key industry trends and regulatory and tax matters impacting funds, managers and investors.

Photo of Rachel Lowe Rachel Lowe

Rachel E. Lowe is a special regulatory counsel in the Corporate Department and a member of the Private Investment Funds Group.

Rachel advises on financial services regulation specializing in sustainable finance and ESG regulation. She has particular expertise in drafting and advising on…

Rachel E. Lowe is a special regulatory counsel in the Corporate Department and a member of the Private Investment Funds Group.

Rachel advises on financial services regulation specializing in sustainable finance and ESG regulation. She has particular expertise in drafting and advising on the Sustainable Finance Disclosure Regulation (SFDR) and the Taxonomy Regulation. Rachel has also supported with EU MiFID and AIFMD sustainability updates for clients, including from a governance and organizational perspective, as well as providing drafting and training support. She also advises on the Corporate Sustainability Reporting Directive (CSRD), including analysis of its applicability for large international group structures.

From a UK perspective, Rachel supports clients with the TCFD-related requirements in the Financial Conduct Authority’s ESG Sourcebook and is increasingly engaged on the UK’s Sustainability Disclosure Requirements (SDR).

More broadly, Rachel has worked with litigation colleagues to assist clients with understanding and mitigating greenwashing-related legal and regulatory risk.

Photo of Sulaiman Malik Sulaiman Malik

Sulaiman Malik is an associate in the Corporate Department and a member of the Private Funds Group.

Sulaiman advises clients on a range of UK and international financial regulation. He advises private equity funds, hedge funds, sovereign wealth funds and other asset managers…

Sulaiman Malik is an associate in the Corporate Department and a member of the Private Funds Group.

Sulaiman advises clients on a range of UK and international financial regulation. He advises private equity funds, hedge funds, sovereign wealth funds and other asset managers, as well as banks, FinTechs, broker-dealers and governments.

Prior to joining Proskauer, Sulaiman trained at Simmons & Simmons in London, where he was seconded to Brevan Howard. He has also spent time at the UK’s Ministry of Justice and as an adviser to the Mayor of Brisbane, in Australia.

Sulaiman is a passionate advocate for diversity and inclusion. He previously worked at Rare, a market-leading diversity consultancy, and provides pro bono legal advice to a range of community and civil rights organizations.

Photo of Michael Singh Michael Singh

Michael is an associate in the Private Funds Group in the Corporate Department.

Michael advises clients on a variety of regulatory issues both from a UK and European perspective. He also helps clients on fund related transactions. His clients include private equity firms…

Michael is an associate in the Private Funds Group in the Corporate Department.

Michael advises clients on a variety of regulatory issues both from a UK and European perspective. He also helps clients on fund related transactions. His clients include private equity firms, investment managers, FinTech companies and wealth management businesses.

He is dual-qualified as a German lawyer (“Rechtsanwalt”) and Solicitor of England and Wales and previously was in-house counsel at Deutsche Bank.