Sanctions list and statutory guidance

IPA Insolvency Practitioner newsletter AML Digest, April 2026

A reminder that as of 28 January 2026, the OFSI Consolidated List is no longer going to be supported and updated. This means from 28 January 2026, no new sanctioned entities will appear on the list.

The Government will only update one sanctions list – the UK Sanctions List – from that date. The search tool works in a very similar way to the OFSI list and holds the same information.

You can start to use the UK Sanctions List immediately and must ensure that any procedure for due diligence is updated so that the UK Sanctions List is now highlighted as the relevant list to search for sanctioned entities.

The search tool can be found here.

Five tips for sanctions compliance:

1. Awareness of sanctions obligations – Insolvency Practitioners must be vigilant when handling assets or transactions that could involve designated persons.
2. Reporting requirements – From 14 May 2025, Insolvency Practitioners will be legally required to report suspected sanctions breaches or frozen assets to OFSI.
3. Policies, procedures & controls – IPs must be able to evidence that they have robust policies, procedures, and controls in place to ensure compliance with sanctions obligations. These should include:
   1. Documented staff awareness and training on sanctions risks.
   2. Due diligence processes to assess potential appointments that may be impacted by sanctions.
   3. Clear internal reporting mechanisms for identifying and escalating sanctions concerns.
4. Risk and compliance – Understanding broader sector risks can help mitigate breaches and ensure appropriate engagement with OFSI where necessary.
5. Guidance on the IPA AML webpage – members will recall the December AML newsletter was a ‘sanctions special’. The information in the newsletter is available on the IPA’s AML webpage and the detail can be found here.

The Government has recently introduced improvements to the structure and wording of their statutory guidance on sanctions to assist in understanding of the requirements and how to effectively use these when required. Details of the improved guidance can be found here.