Cayman Islands Sanctions Update: Switching to the UK Sanctions List
The Cayman Islands Financial Reporting Authority (FRA) has issued a Public Notice confirming that, in line with previous announcements issued by the UK Government, the UK Sanctions List is now the only official list detailing all sanctions designations published by the UK Government.
The UK Office of Financial Sanctions Implementation (OFSI) Consolidated List of Asset Freeze Targets and its search tool are now effectively closed and will no longer be maintained (but the OFSI Consolidated List will remain available for reference).
No changes have been made to the structure of the UK Sanctions List (UKSL).
WHAT IS THE UK SANCTIONS LIST?
The UKSL has been the principal list of sanctions designations made under the UK Sanctions and Anti-Money Laundering Act (SAMLA) since it launched in 2020 and essentially provides a comprehensive list of persons subject to sanctions pursuant to UK regulations made under SAMLA – including financial, trade, immigration and transport sanctions. The UKSL is broader therefore than the OFSI Consolidated List, which had only included information on persons subject to UK financial sanctions.
Sanctions currently in force in the Cayman Islands reflect those imposed in the UK; and it is UK Government policy to ensure that British Overseas Territories such as the Cayman Islands are legally and practically enabled to implement all sanctions designations that are adopted by the UK.
MOVING TO A SINGLE LIST FOR UK SANCTIONS DESIGNATIONS
The UK’s cross-government review of sanctions implementation and enforcement announced, in May 2025, that the UK would be moving to a single list for all UK sanctions designations noting that this shift is responsive to industry feedback to the effect that a single list could remove duplication of effort and simplify checks and screening processes in respect of persons subject to UK sanctions.
As of 28 January 2026, the UKSL became the only official sanctions list that details sanctions designations published by the UK Government. The OFSI Consolidated List and its associated search tool are no longer maintained or updated.
OTHER KEY CHANGES
- The UKSL search tool has been enhanced to implement a ‘fuzzy logic’ search function and rank search results by relevance.
- The ‘Russia: List of persons named in relation to financial and investment restrictions’ is now hosted on a discrete webpage featuring a simplified table (and has not been merged into the UKSL).
- A new set of discrete UK sanctions regime webpages (accessible via the Current UK Sanctions Regimes webpage) have been introduced to host sanctions notices.
- A general Guidance webpage has been made available to help industry use the UKSL as a single source for UK sanctions designations.
RESPONDING TO AND MANAGING THE CHANGE
Sanctions Screening
Any systems that use the OFSI Consolidated List for sanctions screening purposes should be updated to instead use data from the UKSL; and any systems that use an ‘OFSI Group ID’ as an identifier should be updated to instead use the UKSL’s ‘Unique ID’ for new designated persons.
Any Cayman Islands person(s) using a third-party sanctions screening provider are encouraged to speak with such provider in order to ensure that any and all data used for Cayman-compliant screening will incorporate and reflect the relevant data in the UKSL.
Sanctions Licensing and Reporting
All UKSL formats will retain ‘OFSI Group ID’ identifiers for sanctioned persons that were designated as such prior to 28 January 2026; and these historic ‘OFSI Group IDs’ will remain valid for use in sanctions licence applications and/or frozen asset or suspected breach reporting (noting that the new UKSL ‘Unique IDs’ will also be valid for use in this respect).
Ongoing Monitoring
In terms of key broader continuing obligations under the Cayman Islands sanctions and AML/CFT/CPF regimes, any relevant ongoing monitoring and/or searches carried out by Cayman Islands persons in respect of their clients and/or counterparties (as appropriate) should be conducted by reference to the UKSL; and any associated compliance policies and procedures should be reviewed and updated (if required) to reflect the same.
HOW WE CAN HELP
It is important that all Cayman Islands persons understand and act appropriately upon the effective closure of the OFSI Consolidated List and the establishment of the UKSL as the only official source for UK sanctions designations.
Appleby’s Regulatory Team has extensive experience advising on international financial and trade sanctions and their impact on Cayman Islands entities – including in relation to sanctions screening, the implementation and reporting of asset freezes, sanctions licensing, and related matters.
For further information on or assistance with any of the matters referred to in this briefing please reach out to one of the Key Contacts listed below or to your usual Appleby point of contact.
