The United Kingdom entered 2026 with a consolidated and legally structured sanctions framework designed to confront terrorism financing through domestic and international mechanisms. As of 28 January 2026, the UK Sanctions List stands as the single authoritative register of all persons and entities subject to financial restrictions, travel bans, and related prohibitions under British law. This list includes designations made under the Counter Terrorism Sanctions regime, which is grounded in the Sanctions and Anti Money Laundering Act 2018 and implemented through the Counter Terrorism Sanctions EU Exit Regulations 2019. These legal instruments empower the government to identify individuals and organisations suspected of involvement in terrorism financing, support, facilitation, recruitment, or propaganda, and to impose targeted measures aimed at cutting off access to financial systems within United Kingdom jurisdiction.
The updated list as published on 28 January 2026 reflects both continuity and expansion. It consolidates earlier registers, including what was previously known as the Office of Financial Sanctions Implementation consolidated list, into a single searchable framework accessible to the public through the official government portal. The importance of this unified list cannot be overstated. Financial institutions, companies, charities, legal practitioners, and ordinary citizens rely on it to ensure compliance with sanctions law.
Any individual or organisation designated under the counter terrorism regime becomes subject to an immediate asset freeze, meaning that any funds or economic resources owned, held, or controlled by them within the United Kingdom must be frozen without delay.
Legal Foundations of the Counter Terrorism Sanctions Regime
The counter terrorism sanctions framework currently in force in the United Kingdom originates from legislation enacted after the country’s exit from the European Union. The Sanctions and Anti Money Laundering Act 2018 provided the overarching authority for the government to establish autonomous sanctions regimes. Following this, the Counter Terrorism Sanctions EU Exit Regulations 2019 were introduced to maintain and strengthen measures that previously operated under European Union law. The objective was to ensure that the United Kingdom retained the ability to designate individuals and organisations involved in terrorism financing, even after the cessation of EU jurisdiction.
Under these regulations, the Secretary of State has the authority to designate a person if there are reasonable grounds to suspect that the person is or has been involved in terrorist activity. Involvement may include committing acts of terrorism, facilitating terrorism, promoting terrorism, or providing financial services or economic resources for the purposes of terrorism. The designation triggers a set of automatic legal consequences. These include asset freezes, prohibitions on making funds available, and in some cases travel restrictions. The legal test for designation is deliberately framed to balance national security with due process. Designated persons have the right to request a review and may challenge the decision before the courts, ensuring that sanctions are subject to judicial scrutiny.
The 28 January 2026 Update
On 28 January 2026, the United Kingdom government published updated counter terrorism designations under the domestic regime. This update confirmed that certain individuals and organisations were added or maintained on the sanctions list. The publication was accompanied by notices detailing the legal basis for designation, the nature of the restrictions, and the obligations imposed on financial institutions and other entities. Although the government portal does not provide a single downloadable consolidated list categorized exclusively by terrorism financing, the searchable database allows users to filter by regime, including Counter Terrorism Domestic and Counter Terrorism International.
Among the domestic designations publicly confirmed up to early 2026 are individuals such as Kieran James Gallagher and Gurpreet Singh Rehal. Both individuals are subject to asset freezes and director disqualification measures. In addition, organisations such as the New Irish Republican Army, Babbar Akali Lehar, Rampage Productions, and Embers of an Empire have been designated under the domestic counter terrorism framework. These designations illustrate the breadth of the regime, which targets both traditional militant organisations and entities suspected of facilitating financial flows or propaganda activities.
Individuals Designated Under the Domestic Counter Terrorism Regime
The designation of individuals under the domestic regime marks a significant development in the United Kingdom’s approach to combating terrorism financing within its own borders. Kieran James Gallagher, identified as a UK and Ireland national, was designated on suspicion of involvement in terrorist activity and financing or facilitating terrorism. The designation subjects him to an asset freeze, meaning any property or financial assets within UK jurisdiction must be frozen. Additionally, he faces director disqualification, which prevents him from serving as a company director in the United Kingdom. This measure underscores the government’s focus on preventing designated individuals from using corporate structures to channel funds.
Similarly, Gurpreet Singh Rehal, a British national, was designated for alleged involvement in pro terrorist activities and financial support linked to extremist causes. Like Gallagher, Rehal is subject to asset freeze provisions and director disqualification. These measures aim to disrupt not only direct financial transfers but also indirect forms of support, including fundraising, corporate involvement, and financial facilitation. The designation of UK based individuals under a domestic regime demonstrates the government’s intent to address threats that originate or operate within national boundaries rather than solely focusing on international actors.
Organisations Designated Under the Domestic Regime
The New Irish Republican Army, commonly referred to as the New IRA, remains one of the most prominent organisations designated under the domestic counter terrorism framework. The group has been associated with violent militant activities and has been subject to restrictions due to its involvement in acts considered to constitute terrorism under UK law. The designation prohibits any person in the United Kingdom from making funds or economic resources available to the organisation, directly or indirectly.
Babbar Akali Lehar has also been designated for involvement in promoting and recruiting for terrorist causes. The listing reflects concerns about transnational extremist networks and the use of financial channels to support militant agendas. In addition to these groups, entities such as Rampage Productions and Embers of an Empire have been designated on suspicion of facilitating terrorism through financial contributions or dissemination of materials supporting extremist causes. The inclusion of these organisations indicates that the counter terrorism regime addresses not only armed groups but also media or organisational structures that may serve as conduits for funding or propaganda.
Asset Freezes and Financial Restrictions
The most immediate consequence of designation under the counter terrorism sanctions regime is the imposition of an asset freeze. Under this measure, any funds or economic resources belonging to, owned, held, or controlled by a designated person must be frozen. Financial institutions are required to block transactions, report frozen assets to the Office of Financial Sanctions Implementation, and ensure ongoing compliance. The freeze applies to bank accounts, real estate holdings, shares, and other forms of economic value.
Beyond the freezing of existing assets, the regime prohibits any person within UK jurisdiction from making funds or economic resources available to or for the benefit of a designated person. This includes direct transfers, indirect facilitation, and even the provision of goods or services that could be converted into economic benefit. The breadth of this prohibition is intentional. It aims to sever financial lifelines that might otherwise allow terrorist networks to operate or expand. Violations of sanctions law can result in criminal penalties, including substantial fines and imprisonment.
Travel Bans and Director Disqualification
In addition to financial restrictions, designated individuals may face travel bans that restrict entry into or transit through the United Kingdom. While not all domestic counter terrorism designations automatically include travel bans, the government retains the authority to impose them where appropriate. Travel bans are designed to limit the ability of designated persons to engage in international coordination or fundraising activities.
Director disqualification is another important tool. By preventing designated individuals from serving as company directors, the government reduces the risk that corporate entities will be used as vehicles for financial misconduct. This measure reflects lessons learned from previous cases in which corporate structures were exploited to conceal or transfer funds linked to extremist activities. The combination of asset freezes, travel bans, and corporate restrictions creates a layered framework intended to disrupt networks comprehensively rather than in isolated segments.
Domestic Versus International Counter Terrorism Designations
The United Kingdom operates both domestic and international counter terrorism sanctions regimes. Domestic designations target individuals and entities whose activities are linked to terrorism within the United Kingdom or whose support networks are based domestically. International designations, by contrast, often align with United Nations Security Council resolutions or target global extremist organisations.
As of 28 January 2026, the UK Sanctions List includes designations under both regimes, though they are categorized separately within the searchable database. This distinction is important because the legal basis, scope, and reporting obligations may differ between regimes. Financial institutions must carefully verify which regime applies when screening clients and transactions. Failure to do so can result in regulatory penalties and reputational damage.
Practical Implications for Financial Institutions
For banks, investment firms, insurance companies, and other financial service providers, the updated 2026 sanctions list imposes immediate compliance obligations. Institutions must conduct ongoing screening of customers, counterparties, and transactions against the UK Sanctions List. When a match is identified, assets must be frozen without prior notice to the designated person. Institutions are also required to report frozen assets and suspicious activity to the appropriate authorities.
The compliance burden extends beyond large banks. Charities, law firms, property agents, and even small businesses must ensure that they do not inadvertently provide funds or services to designated persons. The complexity of global financial flows makes this a challenging task. However, the unified UK Sanctions List simplifies compliance by consolidating all regimes into a single searchable tool. This consolidation, effective as of 28 January 2026, represents a significant administrative improvement compared to earlier fragmented lists.
Enforcement and Oversight
Enforcement of counter terrorism sanctions falls primarily to the Office of Financial Sanctions Implementation, which operates within His Majesty’s Treasury. The office monitors compliance, investigates potential breaches, and may impose civil monetary penalties. In serious cases, criminal prosecution may be pursued. The enforcement framework emphasizes both deterrence and corrective action.
Oversight mechanisms also include parliamentary scrutiny and judicial review. Designated persons may request a ministerial review of their designation and, if dissatisfied, may challenge the decision in court. This process ensures that sanctions remain grounded in evidence and subject to legal standards. The balance between national security and civil liberties is a recurring theme in the evolution of the United Kingdom’s counter terrorism policy.
Broader Strategic Context
The updated 2026 designations must be understood within a broader strategic context. Terrorism financing is rarely confined to direct cash transfers. It often involves complex networks of donations, shell companies, media platforms, and informal value transfer systems. By designating individuals and organisations suspected of involvement, the United Kingdom aims to disrupt these networks at multiple points.
The domestic regime, in particular, signals recognition that threats can originate internally. The designation of UK nationals and UK based organisations demonstrates that counter terrorism policy is not limited to foreign actors. Instead, it addresses the full spectrum of potential support structures, whether ideological, financial, or logistical. This comprehensive approach reflects lessons learned from previous incidents and investigations spanning more than 2 decades.
Looking Ahead in 2026 and Beyond
As 2026 progresses, further updates to the UK Sanctions List may occur. Designations can be added, varied, or revoked based on new evidence or changing circumstances. The dynamic nature of global and domestic security threats requires flexibility within the legal framework. Financial institutions and businesses must therefore maintain continuous monitoring processes rather than relying on static lists.
The consolidation achieved on 28 January 2026 represents an important milestone, but it is not the endpoint. The effectiveness of sanctions depends on rigorous enforcement, international cooperation, and sustained vigilance. The United Kingdom’s approach reflects a broader global effort to counter terrorism financing through targeted economic measures rather than broad based trade embargoes.
Closing Thoughts
The updated 2026 United Kingdom list of individuals and organisations designated as terrorism financiers reflects a mature and legally grounded sanctions framework. Rooted in the Sanctions and Anti Money Laundering Act 2018 and the Counter Terrorism Sanctions EU Exit Regulations 2019, the regime empowers the government to impose asset freezes, travel bans, and corporate restrictions on those suspected of involvement in terrorism financing or facilitation. The publication of updated designations on 28 January 2026 reinforces the United Kingdom’s commitment to transparency and national security.
For individuals and organisations listed, the consequences are immediate and far reaching. For financial institutions and businesses, the obligations are strict and ongoing. For the broader public, the sanctions regime represents one element of a comprehensive strategy to disrupt terrorist networks by targeting their financial foundations. As the year 2026 unfolds, the effectiveness of these measures will depend on careful implementation, respect for due process, and continued vigilance against evolving threats.
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