RegulationOctober 6, 20268 min read
OFAC vs UN vs EU vs UK sanctions lists: what each one covers
How the four main sanctions lists differ: who publishes them, who must follow them, what they freeze, and why most teams screen all four plus a local list.
A compliance team asked “which sanctions lists do you screen?” usually answers with four names: OFAC, the UN, the EU and the UK. They sound interchangeable. They are not. Each list comes from a different authority, binds different people, and contains designations the others do not.
The short answer
The UN list is the global baseline. The EU and UK lists add the UN designations plus their own. The US OFAC list is the largest and reaches far beyond the US because of the dollar. If you serve customers internationally, you almost certainly need all four, plus the list of the country you are regulated in.
The four lists side by side
| List | Published by | Who must follow it | What it does |
|---|---|---|---|
| OFAC SDN List | US Treasury, Office of Foreign Assets Control | US persons anywhere, and any transaction with a US link, such as US dollar payments cleared through US banks | Property is blocked and dealings are prohibited. Entities 50% or more owned by blocked persons are blocked too. |
| UN Security Council Consolidated List | United Nations Security Council | Every UN member state, which must put the measures into its own law | Asset freezes, travel bans and arms embargoes. The UN itself does not enforce them. |
| EU Consolidated Financial Sanctions List | European Commission, for measures adopted by the Council of the EU | EU nationals and EU companies anywhere, and anyone doing business inside the EU | Asset freeze and a ban on making funds available. Enforced by each member state's authorities. |
| UK Sanctions List | UK Foreign, Commonwealth and Development Office (FCDO) | UK nationals and UK companies anywhere, and anyone in the UK | Asset freeze and related bans. OFSI, part of HM Treasury, enforces financial sanctions. |
OFAC: the list with the longest reach
The Specially Designated Nationals and Blocked Persons List (the SDN list) is maintained by the US Treasury's Office of Foreign Assets Control. US persons, meaning US citizens, residents and companies wherever they are, must block the property of anyone on it and must not deal with them.
It matters to non-US firms too. A US-dollar payment usually clears through a US bank, and that bank must block it if a listed party is involved. OFAC can also impose secondary sanctions on foreign firms that do significant business with certain targets. In practice, almost every international business screens against OFAC.
OFAC also publishes non-SDN lists, such as the Sectoral Sanctions Identifications list. These carry narrower restrictions, like limits on new debt or equity, rather than full blocking. Treating a non-SDN hit as an SDN hit, or ignoring it, are both mistakes.
Finally, the OFAC 50 Percent Rule means an unlisted company can still be blocked if listed parties own 50% or more of it. A name check cannot see that on its own.
UN: the global baseline
The UN Security Council imposes sanctions through its resolutions, and its committees list the individuals and entities they apply to. The measures include asset freezes, travel bans and arms embargoes.
The UN has no police force and fines no one. Each member state must put the measures into its own law. That is why UN designations appear on the EU and UK lists, sometimes after a short delay, and why many national lists are largely UN-derived.
EU: binding across 27 countries
EU sanctions are adopted by the Council of the EU and apply in every member state. The European Commission publishes the Consolidated Financial Sanctions List. It binds EU nationals and EU companies wherever they are, and anyone doing business inside the EU.
The EU list includes UN designations and the EU's own, for example under its Russia regimes. Enforcement is national: each member state's authorities investigate and penalise breaches. EU guidance also looks beyond the list itself to entities that listed persons own or control.
EU banks and payment firms also face the EBA guidelines on sanctions screening controls. Our plain guide to EBA GL/2024/14 explains what they ask for.
UK: one official list since January 2026
Since leaving the EU, the UK runs its own sanctions under the Sanctions and Anti-Money Laundering Act 2018. The FCDO publishes the UK Sanctions List, and since January 2026 it is the single official UK list. OFSI, part of HM Treasury, still enforces financial sanctions, but its old Consolidated List is no longer the source to screen.
If your screening provider still labels its UK data as OFSI’s old consolidated list of targets, ask when it last updated.
Not a sanctions list: FATF
A common quiz question asks which of OFAC, the UN, the EU or the FATF is not a sanctions list. The answer is the FATF. It sets the global anti-money-laundering standards and publishes lists of high-risk countries (the “black” and “grey” lists). Those lists change how much due diligence you do on business linked to a country. They do not name people, and they do not freeze assets.
Why one list is never enough
- The lists overlap but are not identical: each has autonomous designations the others lack.
- Timing differs. A UN listing can reach the EU and UK lists later than it reaches the UN list.
- The same person can be spelled differently on each list, so matching must handle transliteration.
- Your regulator will usually expect your national list as well as the big four.
What to ask a screening provider
- Do you screen OFAC, the UN, the EU, the UK Sanctions List and my local list in the same check?
- How current is each list right now, and can I see that without asking you?
- If one list fails to load, does my result still say “clear”?
- Can you show me, months later, which list versions a past check used?
Verifex can screen OFAC, the UN, the EU and the UK Sanctions List in one check, shows the live state of every list on its public Sources page, and never returns a clear result when a required list was missing. Coverage depends on your plan; see pricing and the full list of sources.
This article explains the lists in general terms. It is not legal advice; confirm which regimes apply to your business with a qualified adviser.
This is educational material about screening operations. Verifex provides screening infrastructure and evidence records, not legal advice, transaction approval, or a replacement for your risk-based compliance program.
All blogQuestions about this topic.
What is the difference between the OFAC, UN, EU and UK sanctions lists?
They are published by different authorities and bind different people. OFAC's SDN list is US law and reaches US persons and US-dollar business. The UN list is a baseline every member state must implement in its own law. The EU and UK lists are binding on EU and UK persons and on business done in those territories. The lists overlap, because the EU and UK add UN designations, but each also has designations the others do not.
Do I need to screen against all four lists?
Most compliance teams do. Which lists you are legally bound by depends on where you are established, where you operate, your customers and the currencies you use. Because US-dollar business can create OFAC exposure for non-US firms, and the EU and UK lists include autonomous designations, screening only one list leaves gaps. Your national regulator may also expect your local list. Confirm the scope with your compliance adviser.
Is the FATF list a sanctions list?
No. The FATF does not publish a list of sanctioned people or companies. It publishes lists of countries: high-risk jurisdictions subject to a call for action, and jurisdictions under increased monitoring. These lists drive enhanced due diligence on business connected to those countries. They do not freeze anyone's assets.
Does OFSI still publish a consolidated list?
The UK moved to a single official list in January 2026: the UK Sanctions List published by the FCDO. OFSI, part of HM Treasury, still enforces UK financial sanctions, but screening should use the UK Sanctions List.
What is the OFAC 50 Percent Rule?
Under OFAC guidance, an entity owned 50% or more, directly or indirectly, individually or in aggregate, by one or more blocked persons is itself blocked, even if it is not named on the SDN list. A name check alone cannot find these entities; you also need ownership information.