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ARTICLE · 07 SEPTEMBER 2026

UK National Security Designations – More Restrictions, More Screening, More Complexity

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The UK has introduced a new designation regime under the National Security Act 2023, creating criminal offences for supporting designated bodies involved in foreign power threat activity. Commercial organizations must now screen against these non-sanctions designations, which carry penalties of up to 14 years' imprisonment and unlimited fines, as the designated entities will not appear on the UK Sanctions List.

GlobalGovernment, Public Sector
Daniel Martin
Daniel Martin
Ryan Whittaker
Ryan Whittaker

Sanctions lists keep growing, with the UK, US and EU continuing to designate individuals and entities under programmes relating to Iran, Russia and Cuba on virtually a daily basis.

As well as the UK’s traditional country programmes, which focus on behaviour at the country level, the past few years have seen growth in the UK’s imposition of so-called thematic sanctions, which focus more on individual behaviour, including cyber activity, corruption and human rights abuses.

Keeping up to date with these programmes is a considerable challenge for commercial organisations, and new developments in the UK have the potential to further increase this challenge significantly. The UK has started to designate particular bodies under non-sanctions legislation, with the result that the designated bodies will not appear on the UK Sanctions List, unless they are separately designated under sanctions legislation.

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