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FinCrime Institute
Category: Sanctions Lists and Screening

HM Treasury Consolidated List

Also known as: OFSI Consolidated List, Consolidated List of Financial Sanctions Targets, HM Treasury Consolidated List of Financial Sanctions Targets in the UK, HM Treasury/OFSI list
Simply put

The HM Treasury Consolidated List was the UK's list of individuals, entities, and ships subject to UK financial sanctions, such as asset freezes. It was maintained by HM Treasury through the Office of Financial Sanctions Implementation (OFSI) and was used to check whether a person or organisation was a sanctions target. This list has now closed, and its designations have been consolidated into the UK Sanctions List (UKSL).

Formal definition

The HM Treasury Consolidated List (the OFSI Consolidated List of Financial Sanctions Targets) was the UK's consolidated register of individuals, entities, and ships designated under UK financial sanctions regimes, maintained by HM Treasury via the Office of Financial Sanctions Implementation (OFSI). It supported screening obligations by setting out designated persons subject to measures such as asset freezes. Per OFSI guidance, from 28 January 2026 the UK Government consolidated its sanctions designations into a single list, the UK Sanctions List (UKSL); the OFSI Consolidated List and its search tool have closed, with the search reflecting designations made only up to 28 January 2026, and the names and details of designated persons now available on the UKSL. A match against this or the successor list is a screening indicator relevant to sanctions compliance and does not by itself establish criminal wrongdoing. Practitioners should confirm current designation sources, scope, and the correct list against the applicable UK sanctions regulations.

Why it matters

For firms with UK sanctions exposure, the HM Treasury Consolidated List was for many years the primary reference for identifying individuals, entities, and ships subject to UK financial sanctions such as asset freezes. Screening customers, counterparties, and transactions against it was a core operational control for obliged entities seeking to detect and manage sanctions risk, and to avoid dealings with designated persons. Because financial sanctions obligations generally apply strictly regardless of intent, having access to an accurate and current list was central to compliance workflows.

The significance of the list has now shifted with a structural change to how the UK publishes designations. Per OFSI guidance, from 28 January 2026 the UK Government consolidated its sanctions designations into a single list, the UK Sanctions List (UKSL). The OFSI Consolidated List and its associated search tool have closed, and that search now reflects designations made only up to 28 January 2026. Firms that continue to rely on the old list or its search tool without transitioning to the UKSL risk screening against outdated data, which could result in either missed designations or false assurance.

It is important to note that a match against this list, or its successor, is a screening indicator relevant to sanctions compliance. It flags a name or entity for further review and does not, by itself, establish criminal wrongdoing. Practitioners should treat matches as prompts for verification and escalation rather than as conclusions, and should confirm the correct current designation source against the applicable UK sanctions regulations.

Who it's relevant to

Sanctions and compliance officers
Professionals responsible for sanctions screening at obliged entities relied on this list to identify designated persons and manage sanctions risk. With the move to the UK Sanctions List, they should ensure screening processes reference the current UKSL rather than the closed OFSI Consolidated List or its search tool, and confirm scope against the applicable UK sanctions regulations.
Financial intelligence analysts and investigators
Analysts using name-matching to review customers, counterparties, and transactions should treat a match against the list, or its successor, as a screening indicator warranting further review and escalation, not as proof of criminal wrongdoing.
Firms with UK sanctions exposure
Any organisation subject to UK financial sanctions obligations needs to transition its screening from the now-closed OFSI Consolidated List to the UK Sanctions List, given that the legacy search reflects designations only up to 28 January 2026 and continued reliance on it risks using outdated data.
Legal and risk professionals
Advisers assessing sanctions compliance should account for the consolidation of UK designations into a single list from 28 January 2026 and verify the correct current designation source and applicable measures against the relevant UK sanctions regulations.

Inside HM Treasury Consolidated List

Consolidated List of Financial Sanctions Targets
A single published list maintained by the UK's Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, that brings together the individuals, entities, and (in some cases) vessels or aircraft subject to financial sanctions under UK law. It is intended as a practical tool to help obliged entities identify designated persons, though the underlying legal authority derives from the relevant sanctions regulations and designation instruments rather than the list itself.
Designated persons and entities
Entries typically identify natural persons, legal entities, and organisations against whom asset-freezing measures or other financial restrictions apply. Each entry generally sets out identifying information such as names and known aliases, dates of birth, nationalities, addresses, and the sanctions regime under which the person or entity is designated.
Regime attribution
Each listing is generally linked to a specific sanctions regime (for example a country-based or thematic regime), which reflects the legal basis for the restriction. The applicable prohibitions and any licensing grounds derive from that regime's regulations, so the regime attribution matters for determining what conduct is restricted.
Identifying data fields and 'group IDs'
Entries commonly include structured identifiers to support screening, such as passport or national identification references where known, and a unique reference for each target. This data is provided to help reduce false and missed matches, though it may be incomplete for some designations.
Machine-readable and human-readable formats
The list is generally made available in formats intended for both manual reference and automated screening, so that obliged entities can incorporate it into transaction and customer screening systems as well as consult it directly.

Common questions

Answers to the questions practitioners most commonly ask about HM Treasury Consolidated List.

Does a name match against the HM Treasury Consolidated List confirm that a customer is a sanctioned criminal?
No. A match against the Consolidated List indicates a potential correspondence between a customer's details and a designated person or entity; it is an alert requiring review, not a determination of wrongdoing or criminal liability. Many alerts are false positives arising from common names, incomplete data, or coincidental matches. Firms are generally expected to investigate and resolve potential matches before taking action, and to escalate confirmed (true) matches in line with their internal procedures and applicable reporting obligations. The list identifies persons subject to financial sanctions measures; it does not itself establish that any individual has committed an offence.
Is the HM Treasury Consolidated List the same as the FATF, EU, or US sanctions lists?
No. The Consolidated List is the UK's own list of persons and entities subject to financial sanctions, maintained by the Office of Financial Sanctions Implementation (OFSI), part of HM Treasury. While it may reflect designations that overlap with other regimes, such as those implementing UN measures, it is distinct from EU sanctions lists, the US OFAC lists (including the SDN List), and any other jurisdiction's lists. FATF does not issue a sanctions list of this kind; it sets standards. Following the UK's departure from the EU, the UK maintains its own autonomous sanctions framework, so designations, scope, and timing can diverge between the UK list and those of other regimes. Firms operating across borders typically screen against multiple applicable lists rather than relying on any one.
Which entities are expected to screen against the HM Treasury Consolidated List?
UK financial sanctions restrictions generally apply broadly to persons within the UK and to UK persons wherever located, meaning obligations are not limited to regulated financial institutions. In practice, firms in scope of the UK's AML framework, such as banks, other financial institutions, and various designated non-financial businesses and professions, commonly use the Consolidated List as a screening tool. However, the underlying prohibitions (for example, on dealing with the funds or economic resources of a designated person) can bind a wider range of parties. Exact scope should be confirmed against the relevant sanctions regulations and OFSI guidance for the specific activity concerned.
How often should the Consolidated List be refreshed within screening systems?
Designations can be added, amended, or removed at short notice, so the list should be treated as a living dataset rather than a static reference. Many firms adopt processes to ingest updates promptly, often on a frequent or automated basis, so that screening reflects current designations, and some also monitor OFSI notifications of changes. The appropriate frequency is generally a risk-based decision informed by the firm's exposure and operational capacity. Exact update mechanics should be aligned with the firm's own policies and current OFSI publication practices, which should be confirmed directly.
What should a firm do when it identifies a potential true match on the list?
Where screening suggests a genuine (as opposed to false positive) match to a designated person or entity, firms typically follow internal escalation procedures, which may include freezing or refraining from dealing with the relevant funds or economic resources and considering whether a report to OFSI is required. Sanctions reporting obligations are separate from AML suspicious activity reporting; a sanctions match may trigger notification duties to OFSI under the sanctions framework, while suspicions of money laundering are reported to the National Crime Agency under the Proceeds of Crime Act. The specific steps, reporting triggers, and timelines should be confirmed against the applicable sanctions regulations and OFSI guidance.
Can relying only on the Consolidated List be treated as sufficient sanctions compliance?
Screening against the Consolidated List is a measure to detect and manage sanctions exposure, but it is not, on its own, a guarantee of compliance or a complete control. The list is one input; firms operating internationally may need to screen against other applicable regimes, and effective sanctions risk management generally also depends on data quality, matching logic, ownership and control analysis (since restrictions can extend to entities owned or controlled by designated persons), and timely investigation of alerts. Reliance on a single list without broader controls may leave residual risk. Firms should calibrate their approach to their risk profile and confirm requirements against current regulations and guidance.

Common misconceptions

The Consolidated List is the same thing as a sanctions law, so being on it is what creates the legal restriction.
The list is an operational and administrative tool published to help firms comply. The legal obligations and prohibitions arise from the underlying UK sanctions regulations and designation decisions, not from inclusion on the list itself. Practitioners should treat the list as a consolidated reference and confirm the applicable prohibitions against the relevant regulations.
Screening against the Consolidated List covers all of a firm's sanctions and financial crime obligations.
The list addresses UK financial sanctions targets, but firms may also be exposed to other regimes (for example those administered by other jurisdictions) depending on their activities and touchpoints. Sanctions screening is also distinct from PEP screening, adverse media screening, and broader CDD or EDD obligations, which serve different purposes and are not satisfied by a sanctions list match.
A name match against the Consolidated List proves the customer is a designated person and establishes wrongdoing.
A screening match is an alert requiring investigation, not a confirmation. Matches may be false positives arising from common names or partial data, and even a true designation is a regulatory status rather than proof of any criminal offence by the customer. Firms generally need to review identifying data and take a risk-based decision before acting.

Best practices

Screen customers and relevant transactions against the current Consolidated List and re-screen when the list is updated, rather than relying on a point-in-time check at onboarding only.
Use the structured identifying fields (such as dates of birth, nationalities, and reference identifiers) to improve match quality and reduce both false positives and missed matches, while recognising that some entries may have incomplete data.
Confirm the applicable prohibitions and any licensing grounds against the underlying UK sanctions regulations for the relevant regime, rather than treating the list entry alone as the full statement of the restriction.
Treat screening alerts as items for investigation and documented human review, and avoid taking adverse or reporting action on the basis of an unverified match.
Maintain a clear, auditable escalation and decision-making process for potential matches, including how true matches are handled and how contact with OFSI or licence considerations are managed where relevant.
Where activities may engage other jurisdictions' sanctions regimes, supplement Consolidated List screening with appropriate additional lists, and keep sanctions screening distinct from PEP, adverse media, and wider CDD or EDD controls.