Changes to the Structure of the UK Sanctions List

Pillsbury - Global Trade & Sanctions Law
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Pillsbury - Global Trade & Sanctions Law

From February 21, 2022, the format of the UK Sanctions List and the UK Office of Fair Trading (OFSI) consolidated list will be different. Businesses must take steps to ensure their systems and processes are configured correctly for the new formatting. In particular, a number of data fields are being updated and seven new fields are being introduced to the OFSI consolidated list.

The changes to the Sanctions List include:

  • the addition of an alias strength indicator for UN listings;
  • the standardization of data to remove duplications, unnecessary punctuation, and to improve consistency;
  • the introduction of new fields to improve the detail and structure of the data;
  • changes to some field names to clarify their purpose;
  • greater alignment between the UK Sanctions List and the OFSI consolidated list; and
  • changes to specific regime ID codes (e.g., the Cyber regime code will change from CY to CYB).

The changes will take effect from February 21, 2022. However, there will be a three-week period in which both the old and new formats of the list will be available. The Foreign, Commonwealth and Development Office (FCDO) will also publish a sample Sanctions List in the new format on January 17, 2022. This should enable businesses to prepare for the change and ensure their systems are set up and tested for a smooth transition.

The FCDO is hosting a webinar on January 19, 2022 to help businesses understand the change and has published guidance.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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