UK Issues Starter Guide to Sanctions Compliance

On 22 September 2025, the UK Foreign, Commonwealth & Development Office (FCDO) released a starter guide on sanctions. The document is designed to help businesses, organisations, and individuals understand their responsibilities when it comes to complying with sanctions law. While not a substitute for legal advice, the guide serves as a practical entry point into one of the most complex areas of compliance.

Who Must Comply

The guidance makes it clear that sanctions compliance has a very wide scope. It applies not only to those operating inside the UK, but also to UK businesses abroad and UK nationals wherever they are located.

• Any individual, business, or organisation operating in the UK (including UK territorial waters).
• Any UK-incorporated business or organisation, regardless of where it operates globally.
• Any UK national, wherever in the world they are based.
  This broad reach means that sanctions obligations cannot be avoided simply by moving operations overseas.

Purpose and Types of Sanctions

Sanctions are not just about freezing assets; they are policy tools used to influence global behaviour. They aim to maintain security, uphold international obligations, and respond to human rights abuses.

• Fulfil UN and international obligations.
• Support UK foreign policy and national security.
• Maintain international peace and security.
• Prevent terrorism and human rights abuses.
  Sanctions may take different forms, including financial restrictions, director bans, trade limitations, travel restrictions, and transport controls.

How Sanctions Work

The guide explains that sanctions can apply to specific named targets or wider groups of people and industries. This makes it critical to check not just lists of sanctioned persons, but also the broader rules of each sanctions regime.

• Designated persons and entities: Subject to travel bans, asset freezes, or arms embargoes.
• Sectoral sanctions: Apply to entire industries or categories of transactions.
• Ownership and control: Sanctions extend to subsidiaries or companies indirectly controlled by a sanctioned person.

Sanctions Lists and Screening

To help businesses know who or what is sanctioned, the government maintains two official lists. Firms must build screening into their compliance processes to avoid accidental breaches.

• The UK Sanctions List – all designated persons, entities, and ships.
• OFSI Consolidated List – asset freeze targets.
  Both lists include identifiers like names, aliases, DOB, nationality, passport details, and roles. Screening can be done in-house or through third-party providers, but the responsibility for compliance remains with the business.

Examples of Sanctions Regimes

The guide uses real-world regimes to show how sanctions vary depending on political and security objectives.

• Libya: Targets human rights violators and individuals linked to the Gaddafi regime.
• Russia: Includes restrictions on finance, trade, oil, and professional services.
• Democratic Republic of the Congo: Prohibits exporting military goods to non-governmental actors.
  These examples highlight that sanctions are both country-specific and thematic, requiring firms to check guidance carefully.

Compliance Essentials

Businesses are reminded that sanctions compliance is not optional – and failing to comply has serious legal consequences. The guide underlines the importance of integrating due diligence into everyday operations.

• Due diligence (KYC): Regular checks on clients, ownership, and control.
• Exceptions and licensing: Certain humanitarian activities may be exempt or licensed.
• Reporting obligations: Firms must report suspected breaches.
• Penalties: Civil fines, prosecutions, or director bans can result from violations.

Key Risks Highlighted

The government also warns against complacency. Sanctions evasion is an evolving challenge, and businesses must stay alert to new risks.

• Circumvention: Any attempt to bypass sanctions, directly or indirectly, is an offence.
• Dual-use goods: Items with both civilian and potential military use require close scrutiny.
• Russian oil price cap: Firms engaged in shipping and services must ensure compliance with strict price caps.

Takeaway: This new FCDO guide is a clear roadmap for sanctions compliance. It stresses that businesses must go beyond basic list-checking, carrying out detailed ownership checks and embedding sanctions awareness across their operations. With regimes growing in complexity, the cost of getting it wrong – financially, legally, and reputationally – has never been higher.