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OFAC vs EU vs UK sanctions: which lists must an EU fund screen?

Last reviewed 24 June 2026.

An EU fund must always comply with EU sanctions — so the EU consolidated list is non-negotiable. It should also screen the UK (OFSI) and US (OFAC) lists wherever it has a UK or US nexus, because designations differ across regimes and US/UK measures can reach beyond their own borders.

EU — always

If your fund is established or operating in the EU, EU restrictive measures apply to you directly. The EU consolidated financial sanctions list is the baseline you must screen against — every issuer, counterparty and investor.

US (OFAC) — where there's a US nexus

OFAC's primary sanctions bind US persons and transactions with a US nexus. The most common trigger for an EU fund is US-dollar payments, which typically clear through the US financial system, but a nexus can also arise from US persons in the chain or US-origin assets. Several US programmes additionally carry secondary-sanctions risk that can affect non-US firms. In practice, an EU fund that touches USD or US counterparties screens OFAC's SDN list too.

UK (OFSI) — where there's a UK nexus

The UK runs its own regime through OFSI, with its own consolidated list. If your activity has a UK nexus — UK counterparties, UK-based service providers, or business conducted in the UK — the UK list is relevant alongside the EU's.

The lists don't line up

This is the crux: the EU, UK and US lists are not harmonised. A name can be designated under one regime but not another, listing dates differ, and the ownership/control tests vary (for example the EU's 50% rule). Screening only the EU list can leave a real exposure under a UK or US designation that still applies to you through a UK or US nexus.

The practical answer for a small fund

  • Screen the EU list always.
  • Add OFAC if you transact in USD or have any US touchpoints.
  • Add UK OFSI if you have UK counterparties or activity.
  • When in doubt, screening all three is the conservative, low-cost default.
Veracore screens your book against the EU list plus OFAC and UK in one run — request a free portfolio screen to see all three on your holdings, or try the free EU checker first.

FAQ

Which lists must an EU fund screen?
The EU list always; plus UK (OFSI) and US (OFAC) wherever there's a UK or US nexus.
Does US OFAC apply to a non-US fund?
It can — via a US nexus such as USD clearing, US persons, or US-origin assets, and through secondary-sanctions risk.
Why not just screen one list?
The regimes aren't harmonised — a designation under one may not appear under another, so one list can miss a real exposure.

Related

EU sanctions screening for fund managers · How often is the EU list updated?