Britain has added 10 Iranian figures and one organisation to its sanctions list over recent protests. The 2 February action names the Interior Minister, regional police chiefs, IRGC operatives and the national police force, FARAJA. Measures take immediate effect and follow EU and US human‑rights listings in recent days, according to the Foreign, Commonwealth & Development Office. For UK boards, this changes the risk picture now, not next quarter. (gov.uk)

Three measures matter operationally. Asset freezes stop any UK person or business from dealing with funds or economic resources owned, held or controlled by the designees, or from making funds or resources available to them, directly or indirectly. Travel bans apply to the individuals. Director disqualification also attaches to these names: designated persons are prohibited from acting as directors or taking part in the management, formation or promotion of a UK company or a foreign company sufficiently connected to the UK. (gov.uk)

FARAJA’s designation will reach beyond the force itself. Under the UK’s ownership and control test, any company it owns (directly or indirectly) by more than 50% of shares or voting rights, can appoint a majority of directors, or can reasonably be expected to direct, is treated as if it were designated. Screening must test control as well as ownership, including de facto influence agreements and board appointment rights. (gov.uk)

Director disqualification creates a governance gate that compliance teams cannot ignore. The Insolvency Service enforces this sanction; acting as a director or being concerned in the promotion, formation or management of a company while designated is a criminal offence. On conviction on indictment, penalties can include up to two years’ imprisonment or a fine. Where a corporate director is itself designated, it cannot serve. Companies should verify appointments and corporate director relationships against the UK Sanctions List before filings. (gov.uk)

Treat today as stop‑and‑verify. If you discover a counterparty is designated, you must stop dealing with them, freeze any assets you hold for them and inform OFSI as soon as possible. Trade restrictions under the Iran regime are separately enforced: the Office of Trade Sanctions Implementation monitors services, goods and technology prohibitions, and criminal breaches of trade sanctions can carry up to ten years’ imprisonment. HMRC retains enforcement powers for strategic goods and customs offences. Seek licences where permitted, but do not proceed until authorised. (gov.uk)

Update screening data. From 09:00 UK time on 28 January 2026, the UK Sanctions List became the single official source for all UK sanctions designations; the OFSI Consolidated List is no longer updated. Systems must migrate to UKSL data and use its Unique ID field for new designations. If you buy screening services, confirm your supplier has switched and enabled fuzzy matching to catch transliterations. (gov.uk)

The enforcement backdrop is clear. Since 15 June 2022, OFSI has been able to impose civil penalties for financial sanctions breaches on a strict liability basis. The maximum civil penalty is the greater of £1 million or 50% of the breach value, and OFSI classifies cases as ‘serious’ or ‘most serious’ when setting fines. Recent actions signal what happens when screening fails or wind‑downs go wrong: Bank of Scotland paid £160,000 over a sanctioned individual’s account, and Herbert Smith Freehills was fined £465,000 for payments routed through sanctioned banks-both after voluntary disclosure. (gov.uk)

A new annual reporting duty now applies. Anyone holding frozen assets for designated persons as at 30 September must submit a return to OFSI by 30 November each year. This replaced OFSI’s information‑request model from 2025 and failure to report without a reasonable excuse can be an offence. Treasury, custody and operations teams should agree ownership of this task well ahead of the deadline. (gov.uk)

Here is how that plays out for a mid‑sized exporter. A Midlands engineering firm using a Gulf agent to access Iranian buyers is due to pay commission next week. If ownership checks identify a link to one of today’s designees or to FARAJA, the firm should block the payment, freeze any sums already held and seek advice on licensing routes under the regulations. Contract clauses should support a suspension while checks conclude. (gov.uk)

This UK step was trailed by ministers and comes alongside EU and US measures. Sanctions moves tend to cluster. Expect more names if violence escalates. For now, firms should refresh training for front‑line teams, tighten approval thresholds for payments to higher‑risk counterparties and keep a weekly sign‑off log while the situation develops. (gov.uk)