Changes to the structure of the UK Sanctions List | Pillsbury – Global Trade Law and Sanctions


From 21 February 2022, the format of the UK Sanctions List and the UK Office of Fair Trading (OFSI) Consolidated List will be different. Businesses should take steps to ensure their systems and processes are properly configured for the new formatting. In particular, a number of data fields are updated and seven new fields are added to the consolidated OFSI list.

Changes to the sanctions list include:

  • added alias strength indicator for UN lists;
  • data normalization to eliminate duplicates, unnecessary punctuation and improve consistency;
  • the introduction of new fields to improve the detail and structure of the data;
  • changed some field names to clarify their purpose;
  • better alignment between the UK sanctions list and the consolidated OFSI list; and
  • changes to specific scheme identifier codes (for example, the Cyber ​​scheme code will change from CY to CYB).

The changes will take effect on February 21, 2022. However, there will be a three-week period during which the old and new list formats will be available. The Foreign, Commonwealth and Development Office (FCDO) will also publish a sample sanctions list in the new format on January 17, 2022. This should allow companies to prepare for the change and ensure their systems are configured and tested for a smooth transition.

The FCDO is hosting a webinar on January 19, 2022 to help businesses understand the change and has released guidance.

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