Does Getting Off the OFAC SDN List Remove You From the UK Sanctions List?

On April 3, 2026, OFAC removed Mikhail Zadornov from the Specially Designated Nationals and Blocked Persons List (SDN List). He had spent four years fighting the designation, first with an administrative petition and then in federal court. The next morning he was still sanctioned in the United Kingdom. London had listed him on May 4, 2022, and reporting on the U.S. removal noted that he remained on the UK and Ukrainian lists.

That sequence catches a lot of people off guard. Getting removed from the SDN List feels like the end of the fight. Then a London bank, a European payment processor, or a shipping company’s compliance screen keeps flagging the name. Usually that’s because another government still lists you, and the U.S. decision did nothing to that listing.

Below we explain how the U.S. and UK lists relate to each other, and the two situations where a U.S. delisting does carry weight in London. We also cover where the EU and Canadian lists fit in.

Does Getting Off the SDN List Remove You From the UK Sanctions List?

No. A U.S. delisting does not revoke a UK designation, and UK law has no rule that removes a person because OFAC did. The UK Sanctions List is maintained by the Foreign, Commonwealth and Development Office (FCDO) under UK law, and you have to ask the UK government separately to take you off it.

The two lists come from different laws. OFAC designates under the International Emergency Economic Powers Act and a series of executive orders, such as Executive Order 14024 for Russia. The UK designates under regulations made under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA), with a separate set of regulations for each sanctions regime. Since January 28, 2026, the UK Sanctions List has been the single official source for UK designations. HM Treasury’s old OFSI Consolidated List closed that day.

When OFAC removes a name, it announces the change in a Recent Actions notice and later in the Federal Register. Nothing in that process sends anything to London. It works the same way in reverse: a UK or EU removal does not touch the SDN List.

Why the U.S. and UK Sanctions Lists Diverge

Plenty of designations were coordinated. In the weeks after Russia’s February 2022 invasion of Ukraine, Washington, London, and Brussels listed many of the same oligarchs, banks, and officials within days of each other. That makes the lists look like one system. They aren’t, and it shows most clearly when someone tries to get off.

The UK applies its own legal test

Under section 11 of SAMLA, a UK minister can designate someone through the standard procedure only if there are “reasonable grounds to suspect” that the person is an “involved person.” The term is broad. Beyond someone who took part in a sanctioned activity, it reaches someone owned or controlled by such a person, someone acting on their behalf, and someone who is “a member of, or associated with” them.

Many UK Russia listings rest on association, and those are hard to overturn. In July 2025, the UK Supreme Court upheld the designation of Eugene Shvidler, a British citizen listed in 2022 because of his association with Roman Abramovich and his former role as a non-executive director of Evraz. The Shvidler decision gives the government wide latitude on foreign policy judgments, so court challenges are an uphill fight.

The facts that won your OFAC case may not answer the UK’s reasons

OFAC evaluates a delisting petition under 31 C.F.R. § 501.807. The question is whether there was an insufficient basis for the designation or whether the circumstances behind it no longer apply. A petitioner who resigned from a board, sold a shareholding, or showed that OFAC had the wrong person can win on those facts.

If the UK listed you on the same facts, that evidence will go a long way in London too. But if the UK listed you because of who you are associated with, a resignation that satisfied OFAC may not address the UK’s stated reason at all.

Can a U.S. Delisting Help You Get Off the UK Sanctions List?

Yes, in two situations. One is narrow and depends on timing. The other applies to almost everyone.

If the UK designated you under the urgent procedure

Since March 2022, SAMLA has allowed the UK to designate a person on an expedited basis when that person is already designated by the United States, the European Union, Canada, or Australia, and the minister considers the designation to be in the public interest. The statute calls these conditions B and C. Together they stand in for the UK’s own “reasonable grounds to suspect” finding, which is condition A.

An urgent-procedure designation lapses after 56 days unless the minister certifies one of two things: that condition A is met, or that conditions B and C are still met. The second option buys one more 56-day period. After that, only condition A can keep the designation in force.

This is where a U.S. delisting matters, because condition B depends on a partner jurisdiction still listing you. If OFAC removes you during that window and no other partner jurisdiction lists you, the minister cannot extend on that basis. The UK then has to establish grounds of its own or let the designation lapse.

The window is short. An urgent-procedure designation can last no more than 112 days before it has to rest on condition A. If the UK listed you in 2022 or 2023, your designation moved onto UK grounds long ago, and this route won’t help.

As evidence in a section 23 review request

For everyone else, the value of a U.S. removal is in the evidence behind it. Under section 23 of SAMLA, a designated person can ask the minister at any time to vary or revoke the designation, using the FCDO’s sanctions review request form.

The OFAC decision by itself usually won’t count for much. OFAC tends to remove names without publishing its reasons, and the UK decides under its own criteria. What carries over is the record you built for OFAC: corporate filings showing the change in ownership, the dated resignation letter, share transfer documents, sworn declarations, and the identity documents that separated you from a namesake. Most of that can be reorganized around the UK statement of reasons and filed in London.

Watch the limit on repeat requests. Once you have made a section 23 request, you cannot make another on the same designation unless it raises “a significant matter which has not previously been considered by the Minister.” A U.S. delisting that arrives after a refused UK request may qualify as that kind of new matter. Still, you’re better off filing the first UK request with the full record than counting on a second chance.

How Do You Get Off the UK Sanctions List?

The UK process has three parts.

1. A section 23 request to the minister. You ask the FCDO to revoke or vary the designation and submit your evidence. SAMLA sets no deadline for the decision.
2. No automatic periodic review. SAMLA used to require ministers to review designations periodically. The Economic Crime (Transparency and Enforcement) Act 2022 repealed that requirement in March 2022. Unless the government acts on its own initiative, nothing happens until you ask.
3. A court challenge to the minister’s answer. Section 38 lets you apply to the High Court (or the Court of Session in Scotland) to set aside the decision on your section 23 request. You can’t take the original designation straight to court. The statute sends you through the minister first. The court applies judicial review principles, and in Shvidler the Supreme Court gave the government considerable room.

Delisting is separate from licensing. The Office of Financial Sanctions Implementation (OFSI) issues licenses that allow frozen funds to be used for things like legal fees and basic living expenses while a review is pending.

What About the EU, Canada, and Other Sanctions Lists?

Each has its own process, and none of them follows the U.S. automatically.

European Union. The Council of the EU lists and delists people by unanimous decision. A listed person can send the Council a request for reconsideration with evidence that rebuts its statement of reasons. They can also bring an action for annulment before the General Court in Luxembourg, which must be filed within two months and ten days of the listing being published or notified. When the General Court annuls a listing, the Council often relists the person on revised grounds, and the new act has to be challenged separately.

The EU’s September 2026 renewal of its Russia sanctions is a recent example of the lists moving on their own. On September 22, the Council removed Alisher Usmanov and Mikhail Fridman from its list as part of a political compromise that renewed the remaining Russia listings for three years. Both men remain on the SDN List and the UK Sanctions List.

Canada. Under the Special Economic Measures (Russia) Regulations and the parallel regulations for other programs, a listed person can apply in writing to the Minister of Foreign Affairs to be removed. The minister decides whether there are reasonable grounds to recommend removal to the Governor in Council. A repeat application requires a material change in circumstances since the last one.

Australia and other countries run their own regimes with their own revocation processes. A U.S. removal is relevant evidence in each of them, but it isn’t decisive in any.

Should You Seek U.S. and UK Delisting at the Same Time?

If you are listed in more than one jurisdiction, treat the delisting as one project with several filings.

• Line up the stated reasons. Get OFAC’s basis for the designation, including the courtesy document available through OFAC’s Reconsideration Portal, the UK statement of reasons on your UK Sanctions List entry, and the EU’s reasons published in the Official Journal. Where they overlap, one body of evidence can serve all three.
• Keep the facts consistent. The U.S., UK, and EU coordinate closely on sanctions. If your timeline or ownership description shifts from one filing to the next, it can undermine all of them.
• Know what the banks screen. Banks, especially correspondent banks and European institutions, screen against U.S., UK, EU, and UN lists at once. Getting off one list may not restore your banking if another listing remains.
• Plan the sequence. Start where your record is strongest. A removal in one jurisdiction does not bind the others, but it does give you a new development to cite.

The U.S. side moves at its own pace. Petitions often take many months, sometimes years. Our guide to how long SDN removal takes covers what drives the timeline, and the Zadornov case study shows how a petition and a federal lawsuit can be sequenced.

Frequently Asked Questions

If OFAC removes me from the SDN List, will the UK remove me automatically? No. The UK Sanctions List is maintained under UK law, and a U.S. delisting does not revoke a UK designation. You need to file a request with the UK government under section 23 of the Sanctions and Anti-Money Laundering Act 2018. Your U.S. evidence can support that request.

If the UK or EU removes me, does OFAC have to follow? No. OFAC decides under U.S. law and its own regulations. When the EU removed Alisher Usmanov and Mikhail Fridman in September 2026, both stayed on the SDN List.

Can I use my OFAC delisting petition in a UK review request? Usually, yes. Corporate records, resignation letters, share transfer documents, and declarations that persuaded OFAC can support a UK request. They still have to answer the UK’s own statement of reasons and legal test.

How long does a UK sanctions review take? SAMLA sets no deadline for the minister’s decision on a section 23 request, so timing varies. There is also no longer any automatic periodic review, so a UK designation can stay in place indefinitely if you never ask.

Talk to a Sanctions Lawyer About Delisting in More Than One Country

Getting off the SDN List is a major result. It doesn’t end other countries’ sanctions, though. The UK, EU, and Canada each require their own filing and apply their own tests, and a U.S. delisting helps most when the evidence behind it gets used in those reviews.

Sanctions Law Center is a Washington, DC firm focused exclusively on OFAC matters. We handle SDN List removal petitions, requests for the record behind a designation, and OFAC litigation when the administrative process stalls. If you are also listed in the UK or EU, we build the U.S. petition so its record can be used in those reviews as well.

Contact us for a free case evaluation.