Sanctions and PEP screening for UK businesses: a practical primer

OFSI handled record sanctions enforcement activity through 2024–25 and published guidance making one thing crystal clear: "we didn't know" is not a defence. The screening burden has moved from banks to everyone else, and the lists change weekly.

UK sanctions are strict liability. You do not need to intend to deal with a sanctioned person to commit an offence — you just need to deal with one.

Who needs to screen

Everyone in the UK is bound by financial sanctions. Regulated firms have an explicit obligation under the Money Laundering Regulations to screen at onboarding and on an ongoing basis.

The lists that matter

• OFSI’s UK consolidated list
• UN sanctions
• EU and US lists (relevant for cross-border trade)
• Domestic regulators’ enforcement notices

PEPs — Politically Exposed Persons

A PEP is someone entrusted with prominent public functions (heads of state, ministers, senior judges, central bank governors, ambassadors and similar) and their close family and associates. PEP status is not an automatic ban — it is a trigger for enhanced due diligence.

Practical screening tips

• Screen the legal entity and the directors and PSCs
• Re-screen at least monthly — lists change constantly
• Use fuzzy matching to catch spelling variants and aliases
• Document every hit and how you resolved it (true match vs false positive) — see our KYC checklist for the wider client file

Handling false positives

Common names produce hits. Resolve them with date of birth, nationality, address or role — not gut feel — and keep a written record. A pattern of unrecorded “not them” decisions is what regulators jump on.

What to do on a true match

Freeze the relationship, do not tip off the subject, and report to OFSI (for financial sanctions) and the NCA (via a SAR) as appropriate. Take legal advice quickly — getting the next 24 hours wrong is the bit that escalates.

Screen once, monitor forever

The point isn't the check at onboarding — it's the one you didn't run six months later when the list moved. CompanyCheckr re-screens watched entities and people daily against UK, EU, UN and US lists, with the audit trail attached. Try a screen or create an account to switch on continuous monitoring.