UK Sanctions List Format Changes – Implications for Financial Institutions

By Alma Angotti, Dave Bradshaw, Liz Holmes

The Office of Financial Sanctions Implementation (OFSI) announced changes in the format of the Sanctions List that impacts Financial Institutions (FIs) and businesses that regularly screen against the UK Sanctions and the OFSI Consolidated Lists. The purpose of the structure changes is to introduce improved consistency, removal of duplications, unnecessary punctuation, and standardisation in the data.

Key areas for the UK Sanctions Lists include additional fields to improve the structure of the data, such as Name Type (Primary, Variation, or Alias), Passport Numbers, Address, and National Identifier. In addition, field names such as Vessel, Regime Type, and Unique ID will change to reflect the type of designation and specific activity for certain regimes. The Consolidated Lists will change to align with the structural changes of the UK Sanctions List through the introduction of seven new fields.


What does this mean for Financial Institutions?

FIs should review their current screening applications to determine the impact in two main areas. The first will depend on how the watch lists are sourced. FIs that employ an external watch list supplier will need to work with the vendor to make the necessary changes to ensure the format changes map correctly to their screening application. Where an internal list management process is in place, FIs will need to test and validate that the full list information is captured. The second action is to review the impact on any existing screening rules, whether used to apply filtering conditions or to reduce false positives, to ensure they continue to work as expected. Examples of this could be where the Vessel field will change to Ship or the name of the OFSI ID field will change to OFSI Group ID. The rule may not recognise the change in the data and therefore not work as intended.


How Guidehouse can help

Guidehouse can rapidly review changes to the UK sanctions regime and assess your financial crime framework to determine whether it is operationally effective and meets the new data format. Guidehouse’s experienced sanctions system specialists will help guide FIs during the transfer of historical sanction system rules and support data mapping from the watch list data to the screening filter. Guidehouse can identify further enhancements through system tuning and advise on optimal solutions to improve efficiency.

Our team has in-depth knowledge of the regulatory environment in the UK, Europe and globally, and best practices operated by financial institutions. Our relevant expertise includes the following: 

  • An assessment of the new list format to determine whether individual rules require updating. This assessment will be conducted through a review of the bank’s data, sanctions policy, and regulator’ expectations.
  • Data Mapping in cases where the list format changes impact internal list management processes.
  • Filter Testing.
  • Hit-rate reduction through rules calibration. 
  • System Configuration.
  • Model Validation.

Guidehouse’s financial crime consultants work with FIs of all sizes to build effective and efficient risk management and compliance frameworks to help clients protect against legal, fiduciary, shareholder, and reputational risk. Guidehouse experts include distinguished former prosecutors, regulators, compliance officers, and consultants, who leverage their combined experience to help clients conquer their compliance challenges.

Alma Angotti, Partner

Dave Bradshaw, Director

Liz Holmes, Associate Director

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