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Comment & Opinion

February 2022 changes to structure and format of UK sanctions lists

What has happened?

The government has published guidance to help businesses and industry understand and prepare for changes to the structure and format of the UK sanctions list and the Office of Financial Sanctions Implementation (OFSI) consolidated list. The changes will apply from February 2022.

What are the changes?

Changes to the UK sanctions list include:

  • Alias strength for UN listings
  • Standardisation of data to remove duplications and unnecessary punctuation, and improve consistency
  • The creation of new fields to improve the detail and structure of the data
  • Changes to some field names to make their purpose clearer
  • Changes to ‘name’ fields so that only SWIFT characters are accepted
  • The introduction of additional file formats to improve the range of data formats available

Changes to OFSI’s consolidated list include:

  • Seven new fields
  • The introduction of a new group type ‘Ship’
  • Retirement of the .xls format

OFSI will publish a new format guide to assist users of the consolidated list.

Steps to take

Organisations should familiarise themselves with the guidance and ensure that their internal systems (including around screening rules and automated tools), policies and procedures are updated and tested to prepare for the changes, and that staff are trained as necessary. A webinar on the changes is taking place on 19 January 2022. There will be a period of three weeks ahead of the changeover when organisations will be able to view the old and new list formats simultaneously.

How we can help

Please do not hesitate to contact Andrew if you need any advice or assistance in relation to these changes or any other issues concerning sanctions and/or trading internationally.

You can access our briefing on managing sanctions and supply chain risk here.

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