Financial sanctions & insolvency

Screen and understand control

Use the current UK Sanctions List and the relevant regime’s legislation. The OFSI Consolidated List closed on 28 January 2026; it is no longer the current source of UK designations.

A name search alone is insufficient. Consider aliases, identifying information and ownership or control by a designated person. A party that does not appear by name may still be affected by restrictions. Reassess when parties, ownership or designations change.

Understand the restriction

An asset freeze limits dealings and the making available of funds or economic resources. It does not mean that ownership passes to the government or to the office-holder. Identify which assets, activities and persons are covered before selecting a course of action.

Exceptions and licensing grounds are specific. An application, or the fact that a payment concerns insolvency expenses, is not permission to pay. Check the terms and scope of any licence and retain evidence of compliance.

Report and record appropriately

OFSI’s guidance explains the reporting obligations of relevant firms, including insolvency practitioners. Apply the statutory knowledge or reasonable-cause tests and any required reporting timescale. Reports about frozen assets and breaches have different purposes.

A sanctions report and an NCA suspicious activity report address different regimes. Record the legal basis for each decision, any restriction on the proposed act and the action taken. Use current official sources rather than a saved list from the appointment date.

Scotland: source route

The AML framework is UK-wide and applies alongside Scottish insolvency law. Distinguish a Scottish company appointment from sequestration, a protected trust deed or DAS work. The scope of the regulated activity and the origin of contributions or third-party funding require their own assessment; the procedure’s title does not answer those questions.