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#38 BreakingUK Sanctions Lists Consolidation

Effective date:took effect on
Components affected:Datasets
Announcement:

tl;dr: Replace all use of gb_hmt_sanctions with gb_fcdo_sanctions (in the API and in bulk data scenarios) by January 28. gb_hmt_sanction will stop receiving new entities and eventually be removed from the database entirely.

Policy Change

The UK government is consolidating its sanctions designation lists into a single source. Starting January 28, 2026, at 09:00 GMT, the UK Sanctions List (UKSL) will become the sole official list for all UK sanctions designations. The OFSI Consolidated List of Asset Freeze Targets and its associated search tool will cease updates from this date.

This consolidation follows the Cross-government review of sanctions implementation and enforcement, responding to industry feedback that a single list will remove duplication and simplify compliance checks.

Impact on OpenSanctions Data

OpenSanctions currently maintains two separate UK datasets:

Following the UK government's consolidation, we will transition to maintaining a single aggregated UK sanctions dataset sourced from the unified UK Sanctions List. We expect this to be a smooth transition:

  • The consolidated UK Sanctions List is already covered by our existing UK FCDO Sanctions List dataset and will be expanded by the UK government on January 28, 2026 to include all sanctions designations
  • The UK government has confirmed that the existing data format and structure of the UK Sanctions List will remain unchanged, so we do not anticipate any processing errors or disruptions
  • By the end of 2025, we will update our data ingestion process to consume both the XML and CSV formats of the UK Sanctions List. This dual-format approach provides redundancy in case one format is published with delays or technical issues
  • The UK HMT Financial Sanctions dataset will not receive updates after January 28, 2026, as the underlying OFSI Consolidated List will no longer be published. These datasets will be formally deprecated on that date, and entities exclusively designated on that list will stop being tagged with the sanction topic.
  • Historic OFSI Group IDs will be preserved in our data for entities designated before January 28, 2026 for another six months for reconciliation purposes. New designations from January 28, 2026 onwards will use the UK Sanctions List's Unique ID as the primary identifier.

For more information, see the UK government's guidance on moving to a single list.