Guidance

Starter guide to UK sanctions

A guide for businesses and organisations that need to understand more about what sanctions are and how they work.

From:
Foreign, Commonwealth & Development Office
Published
22 September 2025

Who must comply with sanctions regulations   

If you do any business that involves transactions, financial services, trading, supplying professional services or insurance, you could be dealing with sanctioned individuals or organisations, or with sanctioned goods and services.     

Sanctions regulations apply to: 

  • any individual, business or organisation undertaking activities anywhere in the UK (including the territorial sea)
  • any business or organisation incorporated or constituted under the law of any part of the UK undertaking activities anywhere in the world
  • any UK national, wherever they are in the world

This guidance outlines what sanctions are, how they work, and how to comply with them. It does not represent legal advice.

Anyone can report a suspected breach of sanctions.

Sanctions regulations impose reporting obligations on certain types of firms – these types are listed in:  

If you are unsure about your obligations in a given case, you should consider seeking independent legal advice.

Overview of UK sanctions

 Sanctions are ‘restrictive measures’ that the UK Government imposes on individuals, businesses, organisations and ships as a policy decision, then made into law. The government puts sanctions in place to fulfil a range of purposes, which include:

  • complying with UN and other international obligations
  • supporting foreign policy and national security objectives
  • maintaining international peace and security
  • preventing terrorism

Sanctions and UK foreign policy is led by the Foreign Commonwealth and Development Office (FCDO). The FCDO can apply sanctions regimes in a specific geographic area (known as ‘geographic regimes’) or along a thematic basis (‘thematic regimes’).

Types of sanctions 

The UK may impose different types of sanctions as part of a sanctions regime. See more details in this guide about: 

  • financial sanctions
  • director disqualification sanctions
  • trade sanctions
  • immigration sanctions
  • transport sanctions

 You can also look up details about which government departments and agencies are responsible for different types of sanctions. 

 How sanctions work

Each sanctions regime has its own particular measures, but the various mechanisms for targeting sanctions are common to many regimes.

Designated persons and specified ships 

Some sanctions measures (such as asset freezes, travel bans or arms embargoes) apply in relation to individuals and entities (businesses, public bodies or other organisations) that have been named as the targets for certain sanctions. The general term ‘designated persons’ covers both individuals and entities.

An asset freeze will apply to all funds or economic resources owned, held or controlled by a designated person. This may include financial assets that are held by a third party which is owned or controlled by the designated person – see Ownership and control.

The government can also, under some regimes , specify ships as being subject to transport or other sanctions. 

You can find out which people, entities and ships are designated or specified on the sanctions lists.

Sectoral sanctions

There are occasions when sanctions apply to a defined group or category of people, where the regulations describe the category. When a sanctions measure applies to a whole sector or type of trade, it is often referred to as a ‘sectoral measure’.

You can check for sectoral sanctions in the guidance about each of the sanctions regimes.

 It’s important to read the sanctions guidance carefully, and use the links to the regulations, to understand whether a sanction applies:

  • only to designated individuals and entities or specified ships, or
  • to a defined sector of industry relating to a country (sectoral sanction), or
  • to all individuals and entities in or from that country

For sanctions that apply to designated persons, you can consult the sanctions lists to see who is named under the regulations and which sanctions have been applied to them.

For sectoral sanctions, the individuals and organisations are not named, so you cannot look at the sanctions lists to identify them. A sectoral measure appears in the regulations and the statutory guidance.  

For more details and examples, see Sanctions regimes.

Reasons for designation

The regulations set out the reasons the government can use for deciding to designate someone.

Example: Libya sanctions regime  

The UK Government can designate persons if there are reasonable grounds to suspect that they have been involved in, for example:

  • the commission of a serious human rights violation or abuse in Libya
  • the commission of a violation of international humanitarian law in Libya
  • activities carried out on behalf of the former regime of Muammar Qadhafi that are implementing or connected to the repressive policies of that regime

The sanctions lists and sanctions screening

The UK Sanctions List contains the names of all designated persons and specified ships, and the sanctions that have been applied to them.

There is also the Consolidated List of Asset Freeze Targets maintained by the Office of Financial Sanctions Implementation (OFSI) in alignment with the UK Sanctions List. The Consolidated List only has details of designations made for the purpose of asset freeze measures.     

Both the UK Sanctions List and OFSI Consolidated List are searchable and available as downloads. The entry for an individual can include their:

  • aliases
  • date of birth
  • place of birth
  • nationality
  • passport details
  • national ID details
  • addresses
  • position (such as employment or an official role)

See more about how to use the sanctions lists, with examples of name and target matches, in section 2 of OFSI’s general guidance.

For timely notifications about all new and updated designations, sign up to get UK sanctions email alerts.

Third party sanctions screening services use the government-provided lists as a basis for providing security checks to financial and other firms. UK businesses have the option to use the lists to check their new and existing customer base, or to use an outsourced commercial sanctions screening service to do this on their behalf.

Sanctions regimes

A regime is a collection of sanctions measures put in place for a particular set of purposes, either relating to a geographic area or along a thematic policy. Each UK sanctions regime is set out in a statutory guidance document which accompanies the regime’s regulations .

This guide is designed to support a reading of the statutory guidance for UK sanctions. While it may be helpful as an introduction, it is not a replacement for the statutory guidance on sanctions, or the regulations themselves.      

The statutory guidance for each regime sets out the purpose of the sanctions in section 1, ‘Prohibitions and requirements’.

Section 1 goes on to list each of the sanctions that are imposed and how. The sanctions could be any or all of:

  • financial
  • director disqualification
  • trade
  • immigration
  • transport (shipping and aviation)

Scope of a sanctions regime 

Some sanctions regimes, for example the Yemen sanctions regime, target just a handful of designated individuals and entities, rather than the whole population.

Sanctions regimes may be related to a theme, rather than centred around designated persons and activities in a particular country. For example the domestic counter terrorism regime names particular individuals and organisations linked with terrorist activity.

Other sanctions regimes prohibit making certain goods or services (including sometimes financial services) available to a ‘person connected with a country’. This means that the regime has a much broader scope.

Example: Russia sanctions regime

You must not ‘directly or indirectly grant or enter into any arrangement to grant a new loan or credit, with a maturity exceeding 30 days to a ‘person connected with Russia’’ where ‘a person connected with Russia’ is: - an individual who is, or an association or combination of individuals who are, ordinarily resident in Russia, - an individual who is, or an association or combination of individuals who are, located in Russia, - a person, other than an individual, which is incorporated or constituted under the law of Russia, or - a person, other than an individual, which is domiciled in Russia.

See the definition in the regulations (section 19A (2))

Other sanctions regimes have prohibitions against a defined group. The meaning is always explained in the regulations.

Example: Democratic Republic of the Congo sanctions regime

Regulation 21 prohibits the export of military goods to a ‘non-governmental person’, where ‘non-governmental person’ means ‘a person who is not the Government of the Democratic Republic of the Congo or its public bodies, corporations or agencies or any person acting on its behalf or at its direction’.

See the definition in the regulations.

Ownership and control 

Asset freezes and some other sanctions also automatically carry down from the designated person to any entity that they own or control.

Good sanctions research – ‘due diligence’ – includes not just checking the sanctions lists, but also examining an organisation’s ownership structure or an individual’s circle of contacts.     

Ownership

When dealing with any new or existing businesses or organisations on your client list, you must ensure that:

  • it is not a sanctioned entity
  • it is not a subsidiary of a sanctioned entity

The subsidiaries of sanctioned entities are not always on the sanctions lists, but they may still be sanctioned through the rule of ‘ownership’.

Example

Entity X is not listed on the sanctions lists. However, your research shows that the majority owner of Entity X is Entity Y – and Entity Y is named on the sanctions lists.

As the ownership and control criterion has been met, Entity X is also subject to the same restrictions as designated Entity Y.

OFSI explains more about this example in their general guidance. It also deals with other scenarios, including minority ownership, joint ownership and aggregation – where more than one designated person has an interest in a business.

Control

A business might be controlled by a designated person if, for example, its transactions are carried out under their direction.

You can read more about how to decide if an entity is owned or controlled in OFSI’s blog: Am I dealing with a sanctioned entity?.

You can read about how to decide if a public body is ‘controlled’ by a designated person in OFSI’s guidance in relation to public officials.

Financial sanctions

Financial sanctions are financial restrictions, such as asset freeze, as well as wider restrictions on investment and financial services.  

Asset freeze

The most common form of financial sanction is an asset freeze. An asset freeze sanction is a requirement to ‘freeze’ the funds or economic resources of a designated person.

Economic resources are assets of all kinds that can be used to obtain funds or exchanged for goods or services. This could include:  

  • precious metals or stones
  • antiques
  • vehicles or properties

See section 3 of OFSI’s general guidance for further information about funds and economic resources, including cryptoassets.

If your business gets possession or control of such funds or assets, or is otherwise dealing with them,  you must immediately freeze them and inform OFSI. 

You do not have to confiscate or transfer the funds – ‘freezing’ means blocking access to them. See OFSI’s blogpost on asset freezes and reporting obligations. 

See section 3 of OFSI’s general guidance for detailed definitions of funds and economic resources.

An asset freeze generally prohibits:

  • dealing with the frozen funds or economic resources held or controlled by a designated person
  • dealing with the frozen funds or economic resources that belong to a designated person, even if someone else is holding them
  • making funds or economic resources available, directly or indirectly, to, or for the benefit of, a designated person (this includes, for example, loans and credit)
  • engaging in actions that, directly or indirectly, circumvent the asset freeze

These prohibitions also apply in relation to entities (businesses or other organisations) that are owned or controlled by a designated person.  

OFSI has specific up-to-date lists of ‘asset-freeze targets’ for each financial sanctions regime.

Example: asset freeze under the Nicaragua sanctions regime

A person (‘P’) must not deal with funds or economic resources owned, held or controlled by a designated person if P knows, or has reasonable cause to suspect, that P is dealing with such funds or economic resources.

See the prohibition in the regulations.

Other financial sanctions

In some sanctions regimes there are prohibitions on providing financial services and undertaking certain financial activities in relation to a sanctioned location or person, including:

  • correspondent banking relationships
  • financial messaging services
  • insuring or reinsuring specified ships
  • investing in companies incorporated in a sanctioned country

These financial sanctions may apply to activities with a wider group of persons than designated persons, such as a ‘person connected with’ a country. The scope that applies is set out in the regulations for each sanctions regime.

Breaches of financial sanctions

You’re in breach of financial sanctions if you, without the appropriate licence:

  • deal with funds or economic assets that are frozen
  • make funds or economic resources available to, or for the benefit of, a designated person, or an entity owned or controlled by a designated person
  • undertake activity prohibited under other financial sanctions
  • engage in actions that, directly or indirectly, circumvent the financial sanctions prohibitions

An investigation of a breach may result in a criminal prosecution, a civil monetary penalty, a warning letter or a disclosure (a publication of the decision that names the responsible party).

Help and support with financial sanctions

For an easy-to-follow overview of financial sanctions, view OFSI’s series of videos.

For more in-depth information, OFSI has collection of guidance to help you understand financial sanctions, including FAQs addressing more technical questions, and advisories and threat assessments about specific risks and how to mitigate these. 

Director disqualification sanctions

Director disqualification sanctions ban sanctioned individuals directly or indirectly from:

  • being a director of a UK company (or of a foreign company that has sufficient connection to the UK)
  • taking part in or being concerned in the promotion, formation or management of a company

See the Insolvency Service’s guidance on director disqualification sanctions, including enforcement and licensing. 

Trade sanctions 

Trade sanctions can include prohibitions on: 

  • the export (or transfer, outward movement, or making available) of goods and technology
  • the import (or acquiring or procuring) of goods and technology
  • providing or procuring services related to sanctioned goods and technology (‘ancillary services’)
  • providing standalone services, such as accounting, legal advisory services or IT consulting, generally known as ‘trade services’

Scope of trade sanctions

Some regimes have a narrow scope, where the only goods that are sanctioned are military and dual-use goods and technology . Other regimes have a much wider scope: for example the Russia sanctions regime sanctions many raw materials, essential and luxury items.

Trade sanctions can apply to activities you carry out with:

  • designated persons only (individuals and entities who are designated for the purposes of certain trade sanctions, such as arms embargoes)
  • a geographic location – for example, it is prohibited to import certain goods from non-government-controlled areas of Ukraine
  • a defined group of people – for example, a named military group, or the government of a country, or ‘persons connected with a country’

How to tell if your goods or trade services are sanctioned

When your goods are consigned to or from a country where a sanctions regime is in place, you must check the statutory guidance for that regime – it lists what goods and trade services are sanctioned in the ‘Trade sanctions’ section. You can check more carefully in the schedules in the relevant legislation, where it defines the sanctioned goods using a descriptive definition or by commodity code.

To check goods by their commodity code, look in the UK Integrated Online Tariff to see what sanctions may apply. Note that the Tariff is not a definitive guide to what is and is not sanctioned.

Military and dual-use goods 

Sanctions regimes where trade sanctions apply often impose sanctions on military goods and technology. These goods are already controlled under Export Controls legislation, but may also be prohibited under sanctions legislation. Military goods specified for the purpose of sanctions are listed in Schedule 2 to the Export Control Order 2008. The regulations may include other named items such as ‘firearms’ or ‘security equipment’.

Many regimes sanction the export of dual-use goods, which are more conventional goods but with a possible military use. The Consolidated list of strategic military and dual-use items that require export authorisation helps you to identify if your goods are dual-use items. Examples of dual-use goods include:

  • certain electrical components
  • certain compressors and valves
  • certain chemicals
  • certain machine tools

Ancillary services – services related to sanctioned goods and technology

Trade sanctions on goods and technology often prohibit providing ancillary services – these are services that ‘support’ or ‘facilitate’ the movement, availability, or acquisition of a sanctioned good or technology. It is therefore often prohibited to provide the following where they relate to sanctioned goods or technology:  

  • financial services, such as banking or insurance services
  • brokering services, such as the introduction of persons as parties to an arrangement or the negotiation of an arrangement
  • technical assistance, such as assembling, maintaining, repairing, or testing the goods or technology

You must check before you provide ancillary services for a product where a sanctions regime is imposed. For example, if you supplied goods prior to the sanctions being imposed, and the goods are now sanctioned, you will most likely have to stop providing the ancillary services.      

Price cap on Russian oil (OPC)

The OPC exception allows the supply or delivery of Russian oil and oil products by ship, as well as provision of associated services – so long as the price paid for Russian oil or oil products is at or below the relevant price cap. The regulations are enforced by OFSI. See more details about the Russian oil services ban.

For queries about the OPC, email oilpricecap.ofsi@hmtreasury.gov.uk

Standalone trade services      

Some sanctions regimes prohibit the direct or indirect provision of certain standalone trade services , that are not connected to any traded goods:    

  • professional and business services (under the Russia sanctions regime) 
    • accounting 
    • advertising 
    • architectural 
    • auditing 
    • business and management consulting 
    • engineering 
    • IT consultancy and design 
    • legal advisory 
    • public relations 
  • energy-related services (under the Russia sanctions regime), such as drilling and well testing
  • infrastructure or tourism-related services to non-government-controlled Ukrainian territories (under the Russia sanctions regime) 
  • interception and monitoring services (under the Russia, Belarus, Iran, Myanmar, Syria and Venezuela sanctions regimes)   
  • mining, manufacturing or computer services (under the Democratic People’s Republic of Korea sanctions regime) 

See these regimes to check if your professional services might be subject to sanctions.

Help and support with trade sanctions

See the Department for Business and Trade’s guidance on trade sanctions.

For specific queries about:

Immigration sanctions

Immigration sanctions relate to designated persons who have a travel ban imposed, and so are excluded from coming to the UK under the Immigration Act 1971. 

Any applications they make for a visa to travel to the UK, including for transit purposes, will be refused. Any foreign national who is subject to a travel ban, and who is currently in the UK, will have their permission to stay in the UK cancelled and steps will be taken to remove them from the UK. See the Home Office guidance for caseworkers.

Transport sanctions

Transport sanctions impose restrictions on the ownership, registration, movement and use of ships and aircraft under certain regimes. This can include restrictions on movements to and from ports, harbours and airports, and the detention of ships and aircraft. The restrictions are different for each regime, and currently apply to the regimes in:

  • Russia
  • Belarus
  • DPRK
  • Libya

Help and support with transport sanctions

See the Department for Transport’s guidance on transport sanctions. For specific queries, email transportsanctions@dft.gov.uk

Exceptions and licensing

Certain activities are exempt from sanctions or are permitted under certain conditions.

Exceptions

An ‘exception’, listed in the regulations, gives an automatic exemption to a given activity. An exception might allow activities for emergencies or humanitarian reasons, for example. Section 3.1 of the statutory guidance for each of the sanctions regimes sets out exceptions to some of the sanctions prohibitions that apply within certain defined circumstances for that regime.    

Licences

If no exception applies, then the activity is prohibited in its entirety. You may be able to use a licence to enable that activity. A licence is written permission for such activity. It might allow payments for basic necessities for designated persons, for example. 

If you are unsure whether an exception applies in your circumstances, you should seek independent legal advice.  

Conducting due diligence

While sanctions legislation does not prescribe any methods of due diligence, you should examine who you are doing business with by running checks – often called ‘Know Your Customer’ (KYC) checks.  

Strong due diligence on counterparties and internal governance is essential. Even for established counterparties, you need to repeat due diligence at intervals to ensure that the risk has not changed. For example, if there has been a change of directors, ownership, or of products traded or services provided.

Circumvention

It can be a criminal offence to intentionally participate in activities if the object or effect of them is, directly or indirectly, to circumvent sanctions or to enable or facilitate a breach of sanctions. Circumvention can also be subject to civil penalties.

The government supports exporters and manufacturers in identifying evasion practices. Guidance to help them develop strategies to mitigate the risk of their goods becoming targets of circumvention includes: 

Guidance and case studies to help relevant firms identify signs of possible financial sanctions circumvention are provided in OFSI’s threat assessment reports.

More information

The UK sanctions page lists the main sanctions guidance documents on GOV.UK and has a search of sanctions content.

Updates to this page

Published 22 September 2025

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