Do I Need To Screen Against Both EU And UK Sanctions Lists?

If your business serves clients or counterparties in both jurisdictions — or your supply chain touches EU Member States — yes. Post-Brexit, the EU and UK regimes diverge, and a person may be sanctioned in one but not the other.

How Do EU Sanctions Differ From UK Sanctions Post-Brexit?

The EU operates a 27-state CFSP regime requiring Council unanimity for designations. The UK runs an autonomous SAMLA regime that can act faster but applies only to UK persons and UK conduct. Listings, scope, and licensing diverge in practice.

Where Can I Find The Official EU And UK Lists?

The EU Consolidated Financial Sanctions List is published by the European External Action Service. The UK Consolidated List is published by OFSI on gov.uk. FirmScreen ingests both directly.

Does FirmScreen Screen Against EU And UK Lists?

Yes. Both lists are included in every FirmScreen check, alongside OFAC SDN and the UN Consolidated List.

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EU vs UK sanctions

How the EU Common Foreign and Security Policy sanctions regime differs from the UK SAMLA regime, and why post-Brexit divergence matters for screening.

DimensionEU (27 Member States)UK (Post-Brexit)

Authority

European Council adopts sanctions; the European Commission and Member State competent authorities implement them.

HM Treasury (via OFSI) administers UK financial sanctions; the Foreign, Commonwealth and Development Office sets foreign-policy designations.

Primary List

EU Consolidated Financial Sanctions List (FSF), maintained by the European External Action Service.

UK Consolidated List of Financial Sanctions Targets, maintained by OFSI.

Legal Basis

Council Decisions and Regulations under the Common Foreign and Security Policy (CFSP), directly applicable across all 27 Member States.

Sanctions and Anti-Money Laundering Act 2018 (SAMLA) and country-specific UK Statutory Instruments.

Geographic Scope

Binds EU nationals and entities anywhere in the world, plus any conduct on EU territory.

Binds UK persons (citizens, residents, and UK-incorporated entities) and conduct in the United Kingdom.

Divergence Since Brexit

Continues to follow the EU CFSP process; any new designation requires Council unanimity.

Operates an autonomous regime — designations may be made faster, but coverage and listings now diverge from EU.

Penalty Maximum

Set by each Member State; varies widely. The 2024 EU directive on sanctions violations introduces minimum criminal penalties from 2025.

Civil monetary penalty up to GBP 1 million or 50% of the breach value, plus criminal liability under SAMLA.

Reporting Obligation

Reporting obligations are set by each Member State competent authority.

Frozen assets and breaches must be reported to OFSI as soon as practicable.

Coverage Of UN Designations

Implements UN Security Council designations directly via Council Regulation.

Implements UN Security Council designations via UK Statutory Instrument.

Practical implication for cross-border firms

Cross-border non-financial institutions — particularly law firms, accountancy networks, art dealers, and TCSPs operating in both jurisdictions — must screen against the EU Consolidated Financial Sanctions File and the UK Sanctions List. See the related comparison: OFAC vs OFSI.

FAQ

Questions firms ask

Common questions about EU and UK sanctions divergence.

Still have a question?
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If your business serves clients or counterparties in both jurisdictions — or your supply chain touches EU Member States — yes. Post-Brexit, the EU and UK regimes diverge, and a person may be sanctioned in one but not the other.
The EU operates a 27-state CFSP regime requiring Council unanimity for designations. The UK runs an autonomous SAMLA regime that can act faster but applies only to UK persons and UK conduct. Listings, scope, and licensing diverge in practice.
The EU Consolidated Financial Sanctions List is published by the European External Action Service. The UK Consolidated List is published by OFSI on gov.uk. FirmScreen ingests both directly.
Yes. Both lists are included in every FirmScreen check, alongside OFAC SDN and the UN Consolidated List.

Screen both regimes in one check

FirmScreen covers EU FSF, UK OFSI, OFAC SDN, and UN Consolidated in a single screening operation.

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