OFAC vs UN vs EU vs UK sanctions lists: what each one covers

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

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

1. Do you screen OFAC, the UN, the EU, the UK Sanctions List and my local list in the same check?
2. How current is each list right now, and can I see that without asking you?
3. If one list fails to load, does my result still say “clear”?
4. 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.