Sanctions screening for accountants: a practical UK client-review workflow

Why sanctions screening belongs in the client file

An accountancy engagement is rarely just a name and an invoice. Your firm may prepare accounts for a company, receive instructions from a director and be paid by another group entity. A useful screening process connects those relationships to the work you are actually being asked to perform.

ACCA recommends considering sanctions at client acceptance and throughout the professional relationship. Its guidance identifies accountants, auditors, tax advisers and trust or company service providers as relevant firms with sanctions obligations. Identity verification and sanctions review answer different questions; completing one does not establish the outcome of the other.^[1]

Make the outcome understandable to someone who did not run the search. A colleague taking over a payroll engagement should be able to see which people were checked, why they were included, what needed review and who authorised the next step. A screenshot labelled “passed” does not explain all of that.

Start with the engagement, not the search box

Before searching, create a short relationship map. Begin with the contracting client, then identify relevant owners, controllers and people giving instructions. Record a company number alongside a legal name wherever available. Keep former names and trading names separate so that a later reviewer can reconstruct the search.

For bookkeeping, consider who authorises payments and which entities your team is handling records for. For a group audit, separate the parent, the audited entity and relevant ownership questions. For a sole trader, avoid turning a trading-name search into an assumed check of the individual. The purpose of this exercise is to make the scope explicit, not to screen every name in a ledger without a reason.

• Record the legal client, the engagement type and the person responsible for acceptance.
• List the people and entities selected for screening, their roles and the reason for inclusion.
• Capture available identifiers accurately; mark missing information as unknown rather than inventing it.
• Identify any separate ownership, geographic or service-restriction questions that a name search cannot resolve.

Use current sources and record the scope of the check

Since 28 January 2026, the UK Sanctions List has been the sole source for UK sanctions designations; the old OFSI Consolidated List is no longer updated. Check that procedures and supplier documentation do not still direct staff to the retired feed.^[2]

Keep the search date distinct from the source publication date and the time a provider last retrieved its data. Those dates answer different questions. If a source is unavailable or a search has not completed, record the interruption and the next action rather than filing an empty result as a completed check.

Decide which additional jurisdictions matter to an engagement with appropriate advice. A multi-list search is useful evidence of what was searched, but the presence of a foreign-list result does not, by itself, explain which restriction applies to a UK engagement. Record the list and programme rather than reducing every result to the same label.

Review possible matches before making a decision

OFSI distinguishes a name match from a target match. Compare the available identifiers; if uncertainty remains after checking the list, OFSI can assist.^[3]

In our suggested review record, separate three things: facts that agree, facts that differ and information you still do not have. A similarity score is a way to prioritise review, not a probability that your client is sanctioned. Avoid closing a result merely because one address differs when the rest of the identity evidence is unresolved.

Illustrative example: an invented client director shares a name with a listed individual. The reviewer records the source reference, compares independently obtained identity details and documents the reason for the decision. If the evidence is insufficient, the file remains unresolved and goes to the nominated senior reviewer. The example describes a process, not a rule that any single identifier automatically clears a match.

A clear name search is not permission to provide every service

UK Russia-related sanctions include restrictions on specified professional and business services, including accounting and auditing, supplied to persons connected with Russia. These are not simply a list of named clients. Scope, exceptions and licensing need a separate assessment against the current government guidance.^[4]

Add a service-scope question to your engagement review when relevant: what is being supplied, to whom, where, and for whose benefit? A firm can have an orderly name-screening file while still leaving that question unanswered. Escalate unfamiliar cross-border work before promising a delivery date; do not ask the screening result to resolve a question it was not designed to answer.

Set an escalation route and keep the evidence usable

Relevant firms must report to OFSI as soon as practicable when the applicable knowledge or reasonable-suspicion threshold is met in the course of business. Do not wait for absolute certainty before assessing that duty.^[3]

Build a procedure that tells staff who can pause affected work, who assesses reporting and licensing, and where advice is recorded. Do not make a routine compliance meeting the only route for an urgent concern. Equally, do not label an unreviewed name hit as a confirmed designated person in the client record.

For continuing engagements, our recommendation is to connect review tasks to meaningful changes: a new owner, a new instruction, a change in payment arrangements or relevant list updates. Assign someone to unresolved items. Measure completion of reviews, not just the number of searches run.

• Save the searched names, identifiers, sources, timestamps and result references.
• Record the reviewer, supporting evidence, rationale and outstanding questions.
• Keep escalation and reporting decisions with the engagement record, with appropriate access controls.
• Export evidence into your retention process instead of assuming a screening provider is your permanent archive.