Brighter Consultancy Blog

Why You Need the FCDO Sanctions List as Well as the OFSI Consolidated List

Written by Darren Temple | Aug 13, 2025 3:55:14 PM

If you work in compliance, you will be very familiar with the OFSI Consolidated List. It’s the UK’s official list of individuals and entities subject to financial sanctions.  It’s the go-to list for screening customers, suppliers, and transactions for asset freezes and investment bans.

But here’s the catch.  If you rely on OFSI alone, you’re missing a huge part of the UK sanctions picture.

What the FCDO List Covers

The Foreign, Commonwealth & Development Office (FCDO) UK Sanctions List is the master record of all UK sanctions made under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA). It includes:

  • Individuals, entities, vessels, and aircraft
  • Every type of measure, not just financial… such as: Travel bans, Transport (e.g., banned vessels), Trade sanctions and Procurement bans
  • Detailed legal references, regime names, and effective dates

Why OFSI Doesn’t Cover It All

The Office of Financial Sanctions Implementation (OFSI) list is narrower by design. It contains only those targets with financial restrictions. Asset freezes, investment bans, or similar measures enforceable by the financial sector.

That means:

  • A vessel banned from UK ports but without an asset freeze? On FCDO, not on OFSI.
  • A person with only a travel ban? On FCDO, not on OFSI.
  • An organisation subject only to trade restrictions? On FCDO, not on OFSI.

 

The Risk of Ignoring FCDO

If you screen only against the OFSI Consolidated List, you risk:

  • Missing non-financial sanctions targets in your supply chain or operations
  • Engaging with banned ships, aircraft, or individuals who are legally off-limits for reasons other than asset freezes
  • Falling foul of UK trade, transport, or immigration controls

Bottom Line

Think of OFSI as your financial compliance tool and FCDO as the full legal map of UK sanctions. For robust compliance, especially in sectors like shipping, trade, or travel you need to check both.

Because when it comes to sanctions, what you don’t know can hurt you.

Don’t let a gap in your checks become a gap in your defences.