A sanctions list is only useful on the day it is current. Screen against a list that was accurate last month, and you have not reduced risk: you have created a paper trail that looks like due diligence but isn't. So which sanctions lists should we actually be using, and how do we know they're right?

This guide answers that question properly. It covers what sanctions lists are, who publishes and updates them, and how to build a defensible, risk-based approach to sanctions screening rather than a single-list shortcut that won't survive a regulator's questions.

What are sanctions lists?

A sanctions list is an official register of individuals, entities, vessels, aircraft and sometimes countries or sectors that are subject to restrictions imposed by a government or international body. These restrictions typically prohibit dealing with the listed party: freezing their assets, blocking transactions, or barring them from certain markets or activities. For an asset manager, screening against sanctions lists is a core part of AML/KYC: you cannot onboard an investor, accept a counterparty or process a payment without first checking whether that party (or anyone with significant influence over it) appears on a relevant list.

Designated persons and entities

Most sanctions lists work by "designation": a named individual or entity is added to the list, along with identifying details such as date of birth, nationality, known aliases and addresses. This is what "sanctions screening" usually means in practice: matching your investor, client or counterparty data against these designated names and associated identifiers, and investigating any potential match before it is cleared or escalated.

Sectoral sanctions vs comprehensive sanctions

Not all sanctions are the same shape. Comprehensive sanctions apply broadly, often to an entire country or regime, prohibiting most or all dealings. Sectoral sanctions are narrower: they restrict specific activities, such as dealing in certain types of debt or equity, or trading with named entities in a particular industry (energy, defence, financial services), while leaving other dealings with that jurisdiction permitted. The US Treasury's Sectoral Sanctions Identifications List (SSI List) is a well-known example of this narrower, activity-based approach, distinct from its broader Specially Designated Nationals list. Understanding which type of sanction applies to a match matters because the compliance consequence and the action required are different in each case.

Who issues sanctions lists, and how often are they updated?

Sanctions lists are not maintained by a single global body. Each major jurisdiction runs its own regime, publishes its own list, and updates it on its own schedule. Understanding the main issuers is the first step in building sensible coverage.

The UN Security Council Consolidated List

The United Nations Security Council maintains a Consolidated List covering individuals and entities subject to UN sanctions measures, typically arising from resolutions on terrorism, proliferation and specific country situations. Because listings originate from Security Council decisions, updates are event-driven rather than scheduled: a new listing appears when the Council or its relevant sanctions committee acts.

OFAC and the US Treasury

The Office of Foreign Assets Control (OFAC), part of the US Department of the Treasury, maintains the Specially Designated Nationals and Blocked Persons List (SDN List) along with several other lists, bundled into its Consolidated Sanctions List, including the SSI List described above. OFAC's lists are widely regarded as among the most actively maintained in the world, with updates published on a rolling basis whenever a designation, delisting or clarification is finalised rather than on a fixed calendar.

The EU Consolidated List

The European Union maintains its own Consolidated List, giving effect to sanctions regimes agreed by the Council of the European Union. EU sanctions apply across member states and are updated as the Council adopts new or amended restrictive measures.

The UK Sanctions List

Since Brexit, the UK has run an independent sanctions regime under the Sanctions and Anti-Money Laundering Act 2018. The UK Sanctions List, maintained and published by the Foreign, Commonwealth & Development Office (FCDO), is now the single source for UK sanctions designations: the separate OFSI Consolidated List of asset-freeze targets closed on 28 January 2026 and is no longer updated. The Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, remains the body that implements and enforces financial sanctions, and UK-regulated firms are expected to screen against the UK Sanctions List.

Other national and regional regimes

Beyond the UN, US, EU and UK, dozens of other jurisdictions maintain their own regimes: Switzerland (SECO), Canada, Australia, Japan, Singapore and others each publish lists that may apply depending on where a fund, its investors or its counterparties are based. For asset managers with cross-border structures, offshore trusts, or investors spanning multiple jurisdictions, this matters more than it first appears: a party clean against OFAC and the EU list may still be designated under a regime you haven't thought to check.

The practical implication: lists change constantly

Sanctions lists are living documents, not static registers. Designations are added, amended and removed on a rolling basis across dozens of regimes simultaneously, driven by geopolitical events rather than a predictable release schedule. A screening programme built around a list refreshed periodically, weekly, monthly, or on an ad hoc manual basis, will always be working from data that is out of date to some degree. That gap, between when a list changes and when your screening reflects it, is where risk sits.

How to choose which sanctions lists to screen against

There is no universal answer to "which sanctions lists should we use." The right answer is specific to your firm, and it should be arrived at deliberately rather than defaulted into. Four factors should drive the decision.

Start with your jurisdictions of operation

Screen against the sanctions regimes of every jurisdiction in which your firm is regulated or operates. A UK-regulated AIFM will need UK coverage as a baseline; a manager with a US adviser entity will need OFAC coverage; a firm with EU-domiciled funds will need the EU Consolidated List. Multi-jurisdictional structures, common among PE, VC and private credit managers with parallel fund vehicles, mean this baseline is often wider than firms initially assume.

Follow your investors and counterparties

Your screening obligations don't stop at your own regulatory footprint. Investors, limited partners, fund-of-funds, family offices and SPVs can be domiciled anywhere, and layered ownership structures can introduce beneficial owners connected to jurisdictions your fund has no direct presence in. Sensible list coverage reflects where your investor base actually sits, not just where your management company is licensed.

Meet your regulator's expectations

Regulators increasingly expect firms to be able to explain and evidence their list selection, not just confirm that screening happened. A defensible answer to "why these lists" references your regulatory footprint, your investor base and your documented risk assessment. A screening programme that can only say "we use one commercial list" is a weak answer to that question, whatever the list's quality.

Set your risk appetite deliberately

Broader coverage is not free: it can increase false positives and review workload if not implemented well. The right approach sets list coverage deliberately against risk appetite, rather than narrowing coverage purely to reduce alert volume. Fund administrators and managers with genuinely global investor bases should expect, and budget for, broader coverage than a single-jurisdiction domestic manager.

The case for broad coverage over a single list

Given how many regimes exist, how independently they operate, and how differently they update, relying on a single list, even a well-known one like OFAC's SDN List, leaves genuine gaps. A UN-listed individual not yet added to a national list, or a party sanctioned under a regional regime with no OFAC or EU equivalent, will not be caught by narrow coverage. The practical answer for most asset managers is broad, continuously maintained coverage across the major global and regional lists relevant to their footprint, not a single-source approach that is easier to build but harder to defend.

If your current sanctions screening relies on a single list or a periodic refresh, it is worth seeing what broad, native coverage looks like in practice. Book a demo with Steward to see the platform's sanctions and screening coverage first-hand.