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The UK Office of Financial Sanctions Implementation “OFSI” has announced that, with effect from February 2022, the structure and data fields included in the UK Sanctions List and OFSI’s consolidated list will be changing.

Businesses and organisations that conduct sanctions checks on their customers, business partners and affiliates should familiarise themselves with the new format, take steps to confirm that automated screening processes are correctly configured for the updated data fields and ensure documented compliance policies are refreshed. 

Key changes include:

  • Addition of an Alias  or Also Known As (“AKA”) strength indication for UN listings. A “weak AKA” is a term for a relatively broad or generic alias that may generate a large number of false hits.  Weak AKAs include nicknames, noms-de-guerre, and unusually common acronyms.
  • Addition of a “Name type” field that will state whether the name(s) given for a listed individual is a Primary name, Primary name variation, or Alias.
  • Additional information will be provided to assist with checking passport numbers and national identity numbers.
  • OFSI’s consolidated list will be updated to align with the UK Sanctions List and will publish its own guidance shortly

It is anticipated that the additional fields of data and reformatted structure will enable better level of accuracy of sanctions screening checks and consistency between the UK Sanctions List and OFSI consolidated lists.

The Guidance is available here. Please do not hesitate to contact a member of the BCLP International Trade team if you would like to understand how these changes may impact your UK compliance programme and what action should be taken ahead of February 2022.

 

This document provides a general summary and is for information/educational purposes only. It is not intended to be comprehensive, nor does it constitute legal advice. Specific legal advice should always be sought before taking or refraining from taking any action.