HM Treasury Sanctions List: What It Is, Who Must Screen, and What a Breach Costs

On 28 January 2026, the UK government closed the Office of Financial Sanctions Implementation (OFSI) Consolidated List and moved all HM Treasury sanctions designations to the UK Sanctions List, the single authoritative database for HMT sanctions from that date. Any compliance team whose screening systems still pointed at the old database was pulling from a frozen dataset that OFSI would no longer maintain. The OFSI Annual Review 2024-25 shows 394 suspected breach cases opened in that reporting year alongside 57 enforcement actions, a volume that confirms this is an actively enforced regime. This guide covers what the HM Treasury Sanctions List contains, who is legally required to run HM Treasury Sanctions List screening, what a breach costs, and how to report a suspected violation.

The HM Treasury (HMT) sanctions list is the UK government’s register of individuals, entities, and vessels subject to financial restrictions under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018). As of 2024-25, it covered 3,750 designated individuals, 968 entities, and 15 ships across more than 30 sanctions regimes, per the OFSI Annual Review 2024-25.

What is the HM Treasury Sanctions List?

The HM Treasury sanctions list names every person, company, and vessel that UK-regulated businesses are prohibited from dealing with financially. It covers financial sanctions specifically (restrictions on funds, assets, and economic resources) and sits within a broader suite of global AML sanction regimes that internationally active organizations are required to screen against. Businesses must check the list before onboarding customers, processing payments, or entering into economic agreements with new counterparties and must rescreen as the list is updated.

From the HM Treasury consolidated list to the UK Sanctions List

Before January 2026, OFSI maintained the Consolidated List of Asset Freeze Targets (widely called the HM Treasury consolidated list or HMT consolidated list) alongside the UK Sanctions List (UKSL) as two separate databases. The UKSL launched in 2020 as the primary SAMLA 2018 register, but many compliance teams kept screening against the older list because legacy workflows were built around it. That changed on 28 January 2026 when OFSI retired the Consolidated List entirely.

The OFSI Consolidated List Search portal remains available for historical lookups, but the data it holds is frozen at the closure date and carries no new designations. Any tool or system sourcing its sanctions data from that portal is no longer fit for current compliance purposes.

What the HMT sanctions list contains?

Each entry on the UK Sanctions List includes the designated person’s full name, aliases, nationality, date of birth where available, and the grounds for listing. Entries now carry a “Unique ID” that replaces the OFSI Group ID used in the old Consolidated List. Compliance teams feeding downstream screening systems need to update any identifier-based lookups to use the new format before running checks.

The list covers designations under SAMLA 2018 across regimes including Russia, Belarus, Iran, North Korea, Myanmar, and counter-terrorism programmes. The financial prohibitions attached to each designation can vary by regime, so confirming a name appears on the list is the starting point, not the end point. The statutory instrument governing each designation sets out exactly what restrictions apply, and reading it is part of a sound compliance process.

How does HMT sanctions list screening work in practice?

“HM Treasury Sanction List Screening” means checking a customer’s name, entity name, or vessel against the UK Sanctions List before and during a business relationship. The obligation applies at onboarding and, for most regulated sectors, continues on an ongoing basis as OFSI updates the list throughout each working day.

Who must screen against the HMT list?

UK financial institutions, payment service providers, and businesses operating under the UK Money Laundering Regulations carry a legal obligation to run HMT sanctions screening. The mandate also extends to law firms, accountants, estate agents, and high-value dealers who handle client funds. Businesses with a UK nexus (meaning they involve UK persons, conduct transactions in sterling, or operate within UK territory) are within scope even if headquartered outside the UK. Effective sanctions screening in this context covers initial checks at onboarding, rescreening when the list is updated, and maintaining an audit trail of every check completed.

What the HM sanctions list screening process involve?

A sound HMT screening process runs the customer’s name and any known aliases against the UK Sanctions List, applies fuzzy-matching logic to catch spelling variations, flags potential matches for analyst review, and records the outcome with a timestamp. The list updates continuously throughout the day, so weekly or monthly batch screening is not adequate for organizations with fast onboarding volumes or high transaction frequency. Systems that screen only at account opening leave a compliance gap. A customer who was clean at onboarding can be designated after that fact, and any subsequent transaction with that person without a hit alert creates a breach. For a broader view of the global watchlists organizations need to cover alongside the HMT list, the required screening scope typically extends to OFAC, UN, and EU registers as well.

HMT sanctions: the enforcement reality

Breaching HMT sanctions carries both civil and criminal consequences. As of April 2026, OFSI’s financial sanctions enforcement guidance sets out a penalty framework that OFSI applies actively, not selectively.

Civil penalties and criminal prosecution

The current maximum civil penalty for a financial sanctions breach is the greater of £1 million or 50% of the breach value, per OFSI’s monetary penalties guidance. A 2025 OFSI consultation proposed doubling that ceiling to the greater of £2 million or 100% of the breach value, with implementation pending parliamentary time. Criminal prosecution remains available for the most serious cases under SAMLA 2018, carrying a maximum sentence of seven years’ imprisonment.

The OFSI Annual Review 2024-25 recorded £37 billion in frozen assets for the period, up from £24.4 billion the previous year, with £22.5 billion sitting under the Russia regime alone, which gives a sense of the compliance exposure for any institution transacting near Russia-connected counterparties.

How to report a suspected HMT breach?

If your organization knows or reasonably suspects that a customer is a designated person, or that a financial sanctions prohibition has been breached, you must report to OFSI as soon as practicable. The report should include the relevant sanctions regime, details of the transaction or relationship involved, and documentation explaining how the breach was identified. OFSI launched online submission forms for breach reporting in July 2025, replacing the previous email-only route. Confidential reporting is also available for whistleblowers who have no formal statutory obligation but become aware of a potential breach during the course of their work.