In England and Wales, control over a counterparty begins with one question: does the person or entity appear on a sanctions list, and does any associated individual hold politically exposed status? These two questions are answered from separate, publicly maintained sources. The extract compiled by VLO Law Firm draws on both and states, in the same document, where each source ends.
The angle is control. A shareholder verifying a target company, a buyer conducting pre-acquisition checks, or a lender assessing counterparty exposure all need the same foundation: a confirmed position on the UK Consolidated List, the OFSI asset-freeze register, and the principal PEP databases covering England and Wales. That position is established before any other layer of analysis begins.
What the extract coversUK Consolidated List (OFSI), HM Treasury asset-freeze notices, and PEP classification under the Money Laundering Regulations 2017 — verified against sources retrieved 13 October 2026. Access conditionThe UK Consolidated List is publicly available without registration. The extract fee covers compilation, cross-referencing, language, and structured delivery — not access to a closed database. DeliverySignal tier: 48 hours. Standard tier: 5 business days. Extended tier: 10 business days. What the extract does not showForeign sanctions regimes not mirrored in UK law, informal PEP relationships not captured in structured databases, and any designation issued after the retrieval date.Source: UK Consolidated List (OFSI) · HM Treasury · retrieved 13 October 2026
What the UK sanctions and PEP sources contain
The UK Consolidated List is maintained by the Office of Financial Sanctions Implementation (OFSI) under HM Treasury. It consolidates designations made under the Sanctions and Anti-Money Laundering Act 2018 and successor statutory instruments. Each entry records the designated person or entity, the legal basis for designation, and any asset-freeze or travel-ban measure attached.
The list is updated without a fixed schedule. A designation can be added, amended, or removed on any business day. An extract therefore carries a retrieval timestamp, not a validity period.
PEP classification in England and Wales is governed by the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017). The Regulations define PEP categories by function: heads of state, members of parliament, senior judiciary, central bank officials, ambassadors, senior military officers, and the immediate family members and known close associates of each. Classification is not a registry entry. It is a legal status derived from function, confirmed by cross-referencing official appointment records and structured commercial PEP databases.
The Financial Conduct Authority (FCA) publishes guidance on PEP treatment under MLR 2017. That guidance does not constitute a searchable PEP register. The extract draws on the guidance to confirm the classification methodology applied.
Source: OFSI UK Consolidated List · https://www.gov.uk/government/publications/financial-sanctions-consolidated-list-of-targets · retrieved 13 October 2026
Source: FCA — PEP guidance under MLR 2017 · https://www.fca.org.uk/firms/financial-crime/politically-exposed-persons · retrieved 13 October 2026
The structure of the extract
The extract is organised in three layers.
The first layer is the sanctions check. It records whether the named individual or entity appears on the UK Consolidated List, the date of retrieval, the version of the list consulted, and the exact entry if a match is found. A negative result is stated as a negative result at a specific date and time — not as a clearance.
The second layer is the PEP classification. It records whether the individual holds a qualifying function under MLR 2017, which category applies, and the source of the appointment record used to confirm or exclude that function. Where a close associate or family member relationship is the basis for classification, the relationship is described and the primary PEP identified.
The third layer is the source log. Every assertion in the extract is linked to the source from which it was drawn, the retrieval date, and the access method. This layer exists so that the extract can be audited independently.
| Layer | Content | Source |
|---|---|---|
| Sanctions check | UK Consolidated List match or confirmed absence | OFSI · HM Treasury |
| PEP classification | MLR 2017 category, appointment record, relationship map | FCA guidance · official appointment records · commercial PEP databases |
| Source log | Retrieval timestamps, access method, version references | Compiled by VLO Law Firm |
Control: what the extract establishes and what it does not
The extract establishes a position at a point in time. It does not establish a permanent status.
A person not on the UK Consolidated List on the retrieval date may be designated the following day. A PEP who leaves qualifying office retains enhanced due diligence status under MLR 2017 for a minimum of 12 months after leaving. The extract records the position at retrieval; it does not project forward.
The extract covers UK designations. It does not cover EU autonomous sanctions, US OFAC designations, UN Security Council listings, or any other foreign regime unless those designations have been mirrored into UK law by statutory instrument. Where a target has exposure to multiple jurisdictions, each regime requires a separate check against its own authoritative source.
The extract covers individuals and entities named in the check request. It does not extend automatically to directors, shareholders, or associated entities unless those persons are named in the same request or included in a higher-tier scope.
This is the ceiling of what the sources allow. It is stated here, before payment, so that the scope of the extract is understood before it is ordered.
The limit of what the sources allow
The UK Consolidated List records formal designations under UK sanctions law. It does not record informal asset freezes, pending designation proceedings, or intelligence assessments that have not yet resulted in a statutory designation. A negative result on the list confirms the absence of a formal designation — nothing more.
PEP databases are compiled from public appointment records, parliamentary registers, and official government sources. They do not capture undisclosed relationships, informal influence, or beneficial ownership structures. A person who exercises political influence without holding a qualifying function under MLR 2017 will not appear in a PEP classification.
The retrieval date is the operative date. Any designation or appointment change after that date falls outside the scope of the extract. For transactions with extended timelines, a refresh check at a later date is a separate instruction.
Where sources disagree — for example, where a commercial PEP database records a function that official appointment records do not confirm — the extract records both positions and identifies the discrepancy. The discrepancy is itself a result.
Where the sources disagree
Commercial PEP databases and official appointment records do not always align. A database may carry a historical entry that has not been updated to reflect a departure from office. An official record may lag a recent appointment. The extract does not resolve these discrepancies by choosing one source over the other. It records both, states the retrieval date for each, and identifies the gap.
This matters for control analysis. A buyer relying on a single commercial database without cross-referencing official appointment records may hold an extract that is technically accurate at the database level but factually outdated. The three-layer structure of the VLO extract is designed to make that gap visible, not to paper over it.
Source: UK Consolidated List (OFSI) · retrieved 13 October 2026 Source: Companies House — PSC register · https://find-and-update.company-information.service.gov.uk · retrieved 13 October 2026
Scope and fixed price
The extract is available at three tiers. The scope at each tier is fixed. The price is fixed. What is not included at each tier is stated in the table.
| Tier | Price | What is included | Not included |
|---|---|---|---|
| Signal | €440 | UK Consolidated List check for one named individual or entity; confirmed retrieval timestamp; negative or positive result stated | PEP classification; close associate mapping; source log; multi-jurisdiction checks |
| Standard | €890 | UK Consolidated List check; PEP classification under MLR 2017 for one individual; appointment record cross-reference; source log | Close associate and family member mapping; Companies House PSC cross-reference; multi-jurisdiction checks |
| Extended | €1,800 | UK Consolidated List check; PEP classification; close associate and family member mapping; Companies House PSC cross-reference for linked entities; full source log; discrepancy notation | Foreign sanctions regimes not mirrored in UK law; legal qualification of findings; representation |
This register is public and free of charge. What the fee covers is the removed path: retrieval, cross-referencing, language, structured delivery, and a stated ceiling of what the sources allow.
FAQ
What is the difference between a sanctions check and a PEP check? A sanctions check confirms whether a named person or entity appears on the UK Consolidated List maintained by OFSI. A PEP check confirms whether an individual holds a qualifying function under the Money Laundering Regulations 2017 or is a family member or known close associate of such a person. The two checks draw on different sources and answer different questions. The Standard and Extended tiers of this extract cover both.
Does a negative result on the UK Consolidated List mean the person is not sanctioned anywhere? No. The UK Consolidated List covers UK designations only. EU autonomous sanctions, US OFAC designations, and UN Security Council listings are separate regimes. A negative result on the UK list confirms the absence of a UK designation at the retrieval date. It does not address other jurisdictions.
How quickly does the extract become outdated? The UK Consolidated List is updated without a fixed schedule. A designation can be added on any business day. The extract is accurate at the retrieval timestamp. For transactions with extended timelines, a refresh instruction at a later date is a separate order.
Can the extract cover a company rather than an individual? Yes. The UK Consolidated List includes both individuals and entities. The Signal tier covers one named subject, whether an individual or a legal entity. PEP classification applies to individuals only; the Standard and Extended tiers include PEP checks for the named individual and, at the Extended tier, associated persons identified through the PSC register.
What happens if a commercial database and an official record disagree? The extract records both positions, states the retrieval date for each source, and identifies the discrepancy. The discrepancy is reported as a finding. No source is treated as authoritative over another without a stated basis.
Sources
- UK Consolidated List (OFSI) · HM Treasury — https://www.gov.uk/government/publications/financial-sanctions-consolidated-list-of-targets — retrieved 13 October 2026
- FCA — PEP guidance under MLR 2017 — https://www.fca.org.uk/firms/financial-crime/politically-exposed-persons — retrieved 13 October 2026
- Companies House — PSC register — https://find-and-update.company-information.service.gov.uk — retrieved 13 October 2026
- Sanctions and Anti-Money Laundering Act 2018 — https://www.legislation.gov.uk/ukpga/2018/13/contents — retrieved 13 October 2026
- Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 — https://www.legislation.gov.uk/uksi/2017/692/contents — retrieved 13 October 2026
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Disclaimer: This report is a factual compilation from official registers and public sources. It is provided for informational purposes only, does not constitute legal advice, and contains no legal qualification of the facts established. VLO Law Firm assumes no liability for actions taken or not taken based on this material. For advice regarding your particular situation, please contact info@vlolawfirm.com.
Author: James Whitfield — Partner, UK & Common Law, VLO Law Firm
