A possible sanctions match is not a hit. You open the list entry, compare it with what you hold on the client — date of birth, nationality and address for a person, registration number and registered address for a company — and record which list you checked, which entry you compared, what differed, who cleared it and on which date. OFSI’s own financial sanctions general guidance draws exactly this line: a name match “does not necessarily mean” the person you are dealing with is the one on the list. The file is where you show that you drew it, and on what evidence.
- Name match or target match: the distinction OFSI draws
- Which list to screen against since 28 January 2026
- Who to screen: the client, its owners and its directors
- Clearing a possible match, step by step
- What to record in the client file
- If it may be a target match: your duty as a relevant firm
- A PEP match is a different question
- When a cleared client needs screening again
Name match or target match: the distinction OFSI draws
Section 2.2 of OFSI’s guidance separates two situations:
- Name match. The name of the person, company or ship you are dealing with matches one or more entries on the list, but the other details do not. OFSI’s example: a match on the name of a listed Syrian general, where your client is 15 and was born in the UK.
- Target match. Your client matches all the information on the list entry.
Between the two sits the case that needs care. OFSI’s own example is a close name match with a similar date of birth but a different address, which it calls a potential target match — possibly a new alias — and says you should contact OFSI immediately.
The guidance is plain about the easy case: “If you are satisfied that the person, entity or ship is not the same as the one on the list, you do not need to take further action.” No further action towards OFSI, that is. Your supervisor will still want to see how you reached that conclusion, which is why the record matters more than the search.
Which list to screen against since 28 January 2026
The UK Sanctions List, published by the Foreign, Commonwealth & Development Office (FCDO), is now the only source for all UK sanctions designations. The OFSI Consolidated List of Asset Freeze Targets closed on 28 January 2026 and is no longer updated.
Two practical consequences for a practice:
- Check what your screening names. A screening record dated after 28 January 2026 that names the OFSI Consolidated List as its source names a list nobody updates. The check should name the UK Sanctions List.
- Use the list’s own identifier. Each entry has a Unique ID. OFSI asks for it in any report about a designated person, and designations made since 28 January 2026 no longer receive an OFSI Group ID. Writing the Unique ID into your file ties your comparison to one specific entry.
You can search the list with the FCDO’s search tool, and sign up on the same GOV.UK page for email alerts when designations change. Many firms also screen against the UN, EU and US OFAC lists because clients and their owners operate across borders. Screening several lists is good practice. Naming them in the file is what makes it evidence.
Who to screen: the client, its owners and its directors
Screening only the client company’s name leaves the most common gap open. Section 4 of OFSI’s guidance explains why: an asset freeze also applies to an entity owned or controlled, directly or indirectly, by a designated person, and “those entities may not be designated in their own right, so their names may not appear on the sanctions list.”
OFSI treats an entity as owned or controlled when the designated person:
- holds, directly or indirectly, more than 50% of the shares or voting rights,
- has the right to appoint or remove a majority of the board, or
- could reasonably be expected to ensure the entity’s affairs are conducted in line with their wishes.
So the names to screen for a UK company client are the company itself, its persons with significant control, the individuals at the end of any ownership chain, and its directors. The AML client file should list every name screened, not just the result.
Clearing a possible match, step by step
- Open the list entry. Note its Unique ID, the regime it sits under and the date the list was last updated.
- Compare identifiers you already hold. For an individual, the UK Sanctions List can include name variations and aliases, date of birth, place of birth, nationality, passport and national ID details, addresses and position. For a company, compare the registration number, country of incorporation, registered address and any previous names. Use what is in your client file: the Companies House record, your identity checks, your engagement documents.
- Decide which case it is. Where one or more hard identifiers differ — a date of birth, a registration number, a country — it is a name match. Where everything aligns, treat it as a target match. Where it is close and you cannot rule it out, it is a potential target match.
- Escalate what you cannot clear. OFSI says that if you are still unsure after consulting the list, you can contact OFSI for assistance. Inside the firm, route it to whoever your procedures name — usually the MLRO — before you deal with the client’s funds.
- Write it down the same day. A cleared match with no written reason is, to a reviewer, an uncleared match.
What to record in the client file
| What to record | Example of a good entry | Why it matters |
|---|---|---|
| Names screened | Company, each PSC, each director, with the spelling used | Shows you screened owners and controllers, not only the client |
| Lists and date | UK Sanctions List, UN, EU, OFAC; list version or date checked | Proves the list was current; shows you did not rely on the closed OFSI list |
| Entry compared | UK Sanctions List Unique ID and regime | Ties the decision to one specific entry |
| Identifiers compared | Date of birth, nationality, address; or company number and country | The evidence behind the conclusion |
| Conclusion | Name match / potential target match / target match | Uses OFSI’s own terms |
| Cleared by and when | Name, role, date | Accountability a reviewer can follow |
| Escalation | MLRO referral, OFSI contact or report, with dates | Shows the unresolved cases went somewhere |
The same entry belongs in the file for every screening, including the ones that found nothing. A dated “no match” against named lists is the receipt that the check happened.
If it may be a target match: your duty as a relevant firm
A firm or sole practitioner that provides accountancy services, advice about tax affairs, or certain trust or company services by way of business is a relevant firm under the UK sanctions regulations (section 5.1.2 of OFSI’s guidance; the definition sits in the “Information and records” part of each regime’s regulations). A relevant firm must inform OFSI as soon as practicable if it knows or reasonably suspects that a person is a designated person, or has breached a prohibition, where that information came to it in the course of its business.
The report must include:
- the information or other matter on which the knowledge or suspicion is based,
- any information you hold by which the person can be identified, and
- if the person is your customer, the nature and amount or quantity of any funds or economic resources you hold for them.
Reports go through OFSI’s online form and should quote the Unique ID from the UK Sanctions List. If you hold funds or economic resources for a designated person, section 3 of the guidance requires you to freeze them and not deal with them. OFSI states that a relevant firm that fails to meet its reporting obligations commits an offence, which may lead to prosecution or a monetary penalty.
A PEP match is a different question
A match against politically exposed person data is not a sanctions finding and does not freeze anything. Regulation 35 of the Money Laundering Regulations 2017 requires you to have systems to determine whether a customer or its beneficial owner is a PEP, or a family member or known close associate of one, and to manage the enhanced risk. When the name belongs to a director rather than an owner, see is your client’s director or owner a PEP? Record a confirmed PEP as a risk factor in your client risk assessment and apply enhanced due diligence, rather than treating it as a sanctions escalation.
When a cleared client needs screening again
A clear result is true on the date it was produced. Designations are added and amended, and ownership changes. OFSI’s guidance asks firms to remain vigilant to any change in a designated person’s stake that takes it above 50%. Screen again:
- when the UK Sanctions List changes (the FCDO email alerts tell you when),
- when the client’s PSCs or directors change at Companies House, and
- at each periodic review under your ongoing monitoring procedure.
Each re-screen gets its own dated entry. A reviewer who samples the file should be able to see every check, not just the latest one.
FAQ
Is a possible sanctions match a reason to stop work for the client?
Not by itself. A name match where hard identifiers differ needs no further action towards OFSI once you are satisfied it is not the listed person. Where you cannot rule it out, treat it as a potential target match: escalate internally and contact OFSI before dealing with the client’s funds.
Do I still need to screen against the OFSI Consolidated List?
No. It closed on 28 January 2026 and is no longer updated. The UK Sanctions List published by the FCDO is the only source for UK designations.
Are accountants required to report to OFSI?
Yes. A firm or sole practitioner providing accountancy services, tax advice or certain trust or company services by way of business is a relevant firm, and must inform OFSI as soon as practicable if it knows or reasonably suspects a person is a designated person or has breached sanctions, where that came to it in the course of business.
Why screen the owners if the client company is not on the list?
Because an asset freeze extends to entities owned or controlled, directly or indirectly, by a designated person, and those entities may not appear on the list themselves. Screening persons with significant control and directors is how you find that link.
How do I clear a false positive in EntityWatch?
Enter the Companies House number. EntityWatch screens the company, its persons with significant control and its directors against the UN, EU, UK Sanctions List (FCDO) and US OFAC lists plus PEP data, and names each list, the names screened and the date in the due diligence note. A possible match is routed to your review — never presented as a confirmed hit — so the conclusion stays yours to make and record. While the client is under monitoring, it screens those names again on a schedule and dates each result.
Next step
Write your first client note free for up to five companies, or see how EntityWatch writes the note and which registers it reads in each country.
Last reviewed 29 September 2026. Author: AddonNordic.
This article explains OFSI guidance and UK regulations as they stood on 29 September 2026 and is not legal advice.
This content was generated with artificial intelligence.