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.
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.
It is good practice to check:
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:
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.