Guidance

UK Sanctions List: change to the list's format

Updated 17 February 2022

The structure and the format of the UK Sanctions List is changing in February 2022. This guidance is to help you understand and prepare for the change. Updates to the list will continue to be communicated separately.

This guidance is for businesses and industry that regularly use the UK Sanctions List and the Office of Financial Sanctions Implementation (OFSI) consolidated list and need to understand the change.

To help you prepare your own systems, fully updated versions of both the new UK Sanctions List and OFSI Consolidated List will be published along with the old formats until close of business 25 February 2022. The links to the old formats will be retired on 28 February 2022.

1. Changes to the UK sanctions list

The changes to the format and structure of the UK sanctions list will include:

• Alias strength for UN listings:

  • the UK Sanctions List published on the 31 January will only include Alias quality information for UN designations

  • if the UN implements a new designation, the designation will appear as a UN designation on the UK Sanctions List

  • Alias quality will be provided for a significant number of designations in the UK Sanctions List, but not all designations. Where absent, this field will be blank

• data will be standardised (where possible) to remove duplications, unnecessary punctuation, and improve consistency

• new fields will be created to improve the detail and structure of the data:

  • the ‘Names 1-6’ field will be aligned with the OFSI Consolidated List on structure. Name type is a new field that is associated with each entry of Names 1-6 and shows whether it is a Primary name, Primary name variation, or Alias

    • Primary name variation and Alias are two separate, discreet name types. Primary name variations are spelling variations of the primary name. Alias refers to name records that are substantively different from the primary name, or are referred to as Alias in the UN Sanctions List (in the case of UN designations)

  • the ‘Address 1-6’ field will be aligned with the OFSI Consolidated List on structure, with the inclusion of Address lines 5 and 6

    • addresses have been standardised where possible to bring the information in the UK Sanctions List in line with the UN Sanctions List and Consolidated List

    • ‘Other’ Country field entries will be removed

    • PO Boxes will be included in address fields but should not be included in Address Postal Code fields

  • the ‘Passport Number’ will have 2 fields (number and additional information). Passport additional information is a new field

    • a new record line will be added for each passport number

  • the ‘National Identifier’ number will have 2 fields (number and additional information). The National Identifier additional information is a new field (and will typically describe the source of number e.g. national identity card)

    • a new record line will be added for each National Identifier number

• some field names will change to make their purpose clearer:

  • ‘Individual, Entity, Ship – Vessel’ will change to ‘Ship’ to align with the terminology used in the Sanctions and Anti-Money Laundering Act 2018 (SAMLA)

  • ‘Regime Type’ will now be ‘Designation Source’. Existing options of UK, UN and both UK and UN designations will continue. However, there will be no dual designations for new designations once the new list is operational

  • for Unique ID codes, some specific regime codes will change. Cyber regime will be changing from CY to CYB. Iran Nuclear regimes will be changing from IWD and IRN to INU. Counter-Terrorism International will be changing from CNT to CTI. There will be no material changes to the regime name or the listings, and the regime number also will not change (e.g. CNT001 will now be CTI001)

  • ‘Last Updated’ will now be the date where updates are made to the UKSL, aligning with the OFSI Consolidated list

  • the name of the ‘OFSI Group ID’ field will be updated

  • the name of the ‘UN Reference Number’ field will be updated: we will now only provide one UN reference number

• ‘Name’ fields will be changing so that only SWIFT characters are accepted

  • all designations have a SWIFT compatible name in the UK Sanctions List

• additional file formats are being introduced to improve range of data formats available: XML, HTML

  • the FCDO has published an XSD alongside the release of its XML format. The XSD can be found on the UK Sanctions List Guidance page

  • the HTML uploaded on the 31 January will use the label “Designation Source” in line with the ODT, ODS and XML formats

  • at present, the UK Sanctions List is not published in CSV format and there are no existing plans to introduce a CSV format

  • FCDO and OFSI have made best endeavours to align the UK Sanctions List and Consolidated List. All discrepancies identified since the sharing of sample data have been rectified

2. Changes to the OFSI Consolidated List

The Office of Financial Sanctions Implementation (OFSI) Consolidated List will also be changing to align with the structural changes of the UK Sanctions List. OFSI has published an updated format guide to assist users of the Consolidated List. Both the UK Sanctions List and OFSI Consolidated List will be updated at the same time.

The changes to the structure of the OFSI Consolidated List include 7 new fields:

• Alias Quality

• Non-Latin Script Alias

• Non-Latin Script Type

• Non-Latin Script Language

• Passport Number

• National Identification Details

• UK Sanctions List Date Designated

Additionally, a new group type, ‘Ship’, has been introduced.

All other existing fields will remain in place and Group IDs will not be changing. The published formats for the Consolidated List can be found below. OFSI’s updated format guide to assist users of the Consolidated List can be found on the Consolidated List page.

3. How to prepare for the change

You should familiarise yourself with this guidance and understand the change coming to the UK Sanctions List to prepare accordingly. We have published the new UK Sanctions List and OFSI Consolidated list format alongside this guidance.

4. When you need to take action

From 31 January until 25 February 2022 you will be able to view up to date versions of both the old and new formats of the UK Sanctions List and OFSI Consolidated List simultaneously. This period began on 31 January and will now end following the close of business on 25 February 2022.

You should use this period to prepare for the formal changeover, before the old format of the UK Sanctions List and OFSI consolidated list are retired. The specific links for the older UK Sanctions List and OFSI Consolidated List files will be retired on Monday 28 February 2022.

The published formats for each list will be as follows:

• UK Sanctions List: ODT, ODS, XML, HTML

• OFSI Consolidated List: XML, HTML, CSV, XLSX, PDF, TXT

5. More information

Find out more by regularly checking the UK Sanctions List for updates. You can also subscribe to OFSI’s email alerts to be kept informed of any changes to OFSI’s consolidated list.