The HMT Sanctions List

Financial sanctions orders prohibit a firm from carrying out transactions with a listed person or organisation (known as the target). In some cases the order will prohibit a firm from providing any financial services to the target.

HM Treasury (HMT) maintains a list of targets, known as the UK Consolidated Financial Sanctions List (HMT list). A breach of a financial sanctions order may be a criminal offence.

Financial Sanctions

Standard anti-money laundering checks do not screen clients against the HMT list. Firms should not confuse HMT’s financial sanctions regime with anti-money laundering procedures.

• Financial sanctions apply to all transactions; there is no minimum financial limit.
• There are around 50 UK individuals and 12 UK entities on the current HMT list. It is not just foreign individuals or entities who are on the list.
• Politically Exposed Persons (PEPs) are not necessarily financial sanction targets.
• Most listed individuals and entities are aware that they are on the HMT list, which is publicly available. The issue of ‘tipping off’ (as set out in the Proceeds of Crime Act 2002) should therefore not generally arise.

It is good practice to check:

• Your existing clients against HMT’s list.
• All new customers prior to providing any services or transactions.
• Any updates to the HMT list.
• Any changes to a client’s details.

HMT provide the list of targets on their website. One option is to download the list in an Excel spreadsheet format so that you can reconcile your clients against this list.

Their website can be found at: 
www.gov.uk/government/publications/financial-sanctions-consolidated-list-of-targets/consolidated-list-of-targets

If you find your client is on the HMT list then you are required to stop any services provided to your client and report this matter, as soon as possible, to HMT’s Asset Freezing Unit.