Two significant changes in the last 12 months have reshaped sanctions compliance for letting agents. This is what happened, and what it means in practice.
If you’re running a letting agency in the UK, you’re now legally required to screen every landlord and tenant against the UK Sanctions List before a tenancy begins. That’s not guidance or best practice. It’s the law.
And recently, that law got more specific.
In eight months, two changes came into force that affect how letting agents carry out sanctions screening. If your process hasn’t been reviewed since last spring, there’s a reasonable chance it’s incomplete, out of date, or both.
What changed, and when
14 May 2025: Letting agents formally became ‘relevant firms’
Before this date, the obligation to screen for financial sanctions sat primarily with estate agents. From 14 May 2025, that duty extended to all UK letting agents, regardless of whether they’re registered for Anti Money Laundering (AML) supervision.
Screening landlords, tenants, and guarantors against the UK’s official sanctions list became a standalone legal requirement – separate from, and additional to, any AML obligations a firm might already hold. Failure to comply can result in civil penalties or criminal prosecution.
See the full OFSI guidance for letting agents: Financial sanctions guidance for letting agents (GOV.UK)
28 January 2026: The old OFSI list closed. The UKSL is now the only source.
Until January this year, UK sanctions data was split across two separate lists: the UK Sanctions List (UKSL), published by the Foreign, Commonwealth and Development Office (FCDO), and the OFSI Consolidated List of Asset Freeze Targets, maintained by HM Treasury. Most screening tools pulled from one or both.
On 28 January 2026, the OFSI Consolidated List closed and is no longer updated. The UKSL is now the single authoritative source for all UK sanctions designations. If your screening tool or manual process still references the OFSI list, it’s working from incomplete data.
For details on managing the transition: Moving to a single list for UK sanctions designations (GOV.UK)
Even if a match is only suspected, not confirmed, you are legally required to report it to OFSI. The obligation is to report knowledge or reasonable suspicion.
Why a one-off check at onboarding isn’t enough
A sanctions check at onboarding tells you whether someone is a designated person today. It says nothing about tomorrow.
Individuals and entities can be added to the UK Sanctions List at any point. A landlord who passes a clean check in January could be designated in April. Without ongoing monitoring, your firm has no way of knowing.
This is where continuous watchlist monitoring becomes necessary. It runs in the background, screening your existing clients against the live list, and alerts you if anyone’s status changes mid-relationship. For a letting agency managing hundreds of active clients, that automated alerting is the difference between catching a potential breach and missing it entirely.
What a compliant screening process looks like
To meet the current requirements, your sanctions screening process should:
- Screen against the UKSL, not the old OFSI list. The consolidated list closed in January 2026. Your tool needs to pull from the current source. Amiqus Watchlist checks the screen directly against the UKSL as standard.
- Run automatically when onboarding. Every new landlord, tenant, and guarantor. If your firm also carries out estate agency work, the same applies to sellers and buyers. No manual step, no relying on a team member remembering to run it.
- Monitor continuously, not just at the start. Watchlist monitoring means you’re alerted if someone becomes a designated person after onboarding. Amiqus Watchlist Monitor does exactly this, screening your active clients on an ongoing basis and flagging any changes in designation status automatically.
- Produce a clear audit trail. Timestamped records of who was screened, when, and against which list. Retrievable without friction if OFSI or your regulator ever asks.
Manual checking against a government portal satisfies none of these criteria reliably. It’s slow, it produces no automatic audit record, and it creates the kind of gaps that become problems under scrutiny.
Where Amiqus comes in
Amiqus automates sanctions screening as part of your client onboarding workflow. Our Watchlist check screens individuals against the UK Sanctions List, PEP lists, and adverse media sources every time a new check is triggered. Watchlist Monitor extends that to continuous screening, so your team is automatically alerted to any changes in designation status throughout the relationship.
Every check produces a timestamped, audit-ready record. No manual logging, no spreadsheet tracking, no chasing.
If you’re already an Amiqus client and you’re not sure whether sanctions screening is built into your current templates, your relationship manager can check that with you in a few minutes.
Already an Amiqus client?
Speak to your relationship manager or contact [email protected]
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Prepared by: Reza Karimi, Senior Relationship Manager, Amiqus
