Reporting a sanctions match to OFSI

Most possible matches are not the person in front of you. Occasionally one is, and the working day changes shape. This is the sequence for that day: what to stop, what not to say, what to send, and what to keep. Since 14 May 2025 UK letting agents must screen all landlords, tenants and guarantors at any rent level and report suspected designated persons to OFSI — the Office of Financial Sanctions Implementation, part of HM Treasury.

SafeLet is a screening aid, not legal advice. On a live match, get your own advice early — this page will help you brief whoever you ask.

Last reviewed August 2026.

1. Stop making funds and economic resources available

Before anything else, stop the flow. In a lettings context that usually means:

• Do not release rent to the party you suspect, and do not pass it on through a client account.
• Do not release a deposit, and do not net it off against anything.
• Do not grant, renew or extend a tenancy to the subject, and do not hand over keys.
• Do not deal with the property on the instructions of a suspected designated landlord.

Freezing is not a punishment you are imposing and it is not you deciding the case. It is the default position while the identification is unresolved, because breaching financial sanctions is a criminal offence and OFSI can also impose monetary penalties and publish details of a breach. Continuing to pay rent while you "look into it" is the exposure.

2. Do not tip off

This is where well-meaning firms create a second problem. Disclosing information likely to prejudice an investigation, or telling the subject that a report has been made or may be made, can be an offence in its own right. In practice:

• Say nothing about the screening, the match, the list or the report — to the tenant, the landlord, the guarantor, the contractor or the branch WhatsApp group.
• Keep any operational message minimal and factual. "We are unable to process this payment at present" is very different from "you have come up on a sanctions check".
• Restrict internal knowledge to the people who need it, and put the detail in the case record rather than in email threads.

Take advice on wording if you have to say anything at all. The line between a necessary operational message and a disclosure is exactly where you want a lawyer's view rather than a guess.

3. Nail down the identifiers

Before you report, assemble what you actually know, separating fact from inference. The method for that comparison is in how to screen a tenant against the UK Sanctions List. You want:

• the name as you hold it and the name as the list holds it, including aliases;
• date of birth, nationality, place of birth and document numbers, with the document each came from;
• the designation itself — the regime and the list entry you matched to;
• the tenancy role and the money involved: what has been paid, when, by whom, to whom, and what is now held.

Do not delay a report for days polishing this. Suspicion is the trigger, not proof. Send what you have and say what you are still checking.

4. Report to OFSI as soon as practicable

OFSI publishes a reporting form on GOV.UK for suspected designated persons and suspected breaches; use it rather than an ad hoc email, because it asks for the fields OFSI needs and gives you a clean record of what you sent. Include your own contact details and be specific about what you have frozen and when you froze it.

Two adjacent points worth knowing. First, reporting to OFSI does not discharge any other reporting obligation you may have — a money laundering suspicion is a separate route, and the two are not substitutes. Second, some arrangements involving a designated person can be permitted by an OFSI licence; that is OFSI's decision to make, not an assumption for you to act on.

5. Keep the evidence of what you did

Afterwards, the file should be able to show all of it: the screening result and the list editions behind it, the review notes and who wrote them, the decision to freeze and its timestamp, the report reference from OFSI, and any subsequent correspondence or licence. Keep it under the same retention rule as your other screening records, and make sure it survives staff changes — the person who handled it may not be there when it is asked about.

If you have not yet read the underlying duty, it is set out in UK sanctions checks for letting agents.

Frequently asked questions

When does a possible match become something I have to report?

When you know or suspect you are dealing with a designated person. Suspicion is a lower bar than certainty: you do not have to prove the identification before reporting, and waiting for proof while continuing to take rent is the position that causes the problem. Report as soon as practicable.

Can I tell the tenant or landlord why the payment has stopped?

Be extremely careful. Disclosing information that is likely to prejudice an investigation, or telling the subject that a report has been or may be made, can itself be an offence. Say nothing about the screening, the match or the report; keep any operational message factual and minimal, and take your own legal advice on wording.

What should the report to OFSI contain?

Who you believe the designated person is and why, the identifiers you relied on, your relationship to them and the role they play in the tenancy, the funds or economic resources involved including any amounts and dates, what you have frozen or stopped, and your own contact details. OFSI publishes a reporting form on GOV.UK; use it rather than an ad hoc email.

Does reporting to OFSI mean the tenancy has to end?

Not automatically, and it is not a decision to take on your own reading of the regulations. Some payments and arrangements involving a designated person can be permitted under a licence, and OFSI is the body that grants them. Report first, do not make funds or economic resources available in the meantime, and take legal advice on the tenancy itself.

SafeLet screens against the UK Sanctions List, the US OFAC SDN list and the EU consolidated list. It is a screening aid, not legal advice, and it does not cover politically exposed persons or adverse media. Every possible match requires human review, and suspected designated persons must be reported to OFSI.