AI agents for business finance: what they can and can't do
What AI agents can do in bookkeeping, close, collections and compliance today, where a person must stay in charge, and how to judge a product.
The short answer
Search every Nigerian supplier, buyer, director and owner on the UK Sanctions List, which since 28 January 2026 is the only source of UK designations (the old OFSI Consolidated List is closed). UK financial sanctions apply to UK persons wherever they are, cover entities a designated person owns or controls (more than 50% of shares or voting rights, among other tests), and a possible match is taken to OFSI rather than settled by guesswork.
Most Nigerian companies you will ever trade with have nothing to do with sanctions. The point of screening is not suspicion of Nigeria; it is that UK law makes you responsible for not paying, or receiving value from, a designated person, and a supplier you met on WhatsApp can have owners you have never heard of. A ten-minute check before the first invoice is cheap; unwinding a frozen payment is not.
Where to check: one list since January 2026
The UK Sanctions List, published by the Foreign, Commonwealth & Development Office, lists the people, entities and ships designated under regulations made under the Sanctions and Anti-Money Laundering Act 2018. GOV.UK states that it is "now the only source for all UK sanctions designations". The OFSI Consolidated List of Asset Freeze Targets closed on 28 January 2026 and is kept only for reference, so screening tools or spreadsheets still pointing at it are out of date.
- Search tool: the list has an online search service, with a user guide added in February 2026.
- Downloads: CSV, XML, ODS, ODT, HTML, text and PDF versions, useful if you screen a supplier file in bulk.
- Identifiers: new designations from 28 January 2026 carry a UK Sanctions List Unique ID; quote it in any report to OFSI.
- Alerts: FCDO, OFSI and OTSI run a joint email alert service, so you hear about new designations rather than finding out at payment time.
Who and what to screen on a Nigerian deal
Screening only the company name on the invoice misses most of the risk. OFSI's general guidance says an asset freeze covers funds and economic resources of a designated person and of entities they own or control, and that making funds available "directly or indirectly" to them, or for their benefit, is prohibited. That shapes the list of names to run.
- The Nigerian company itself, under its registered name and any trading name on its invoices.
- Its directors and the shareholders who own or control it. A CAC status report shows these; see how Nigerian trade documents fit together for the paperwork side.
- The bank account holder named on the payment instructions, if different from the supplier.
- Any agent, freight forwarder or third party you are asked to pay instead of the supplier.
- The vessel, where you charter or book a named ship, since the list also covers ships.
The ownership and control test
Under section 4.1 of the guidance, an entity is owned or controlled by a person if that person holds, directly or indirectly, more than 50% of the shares or voting rights, has the right to appoint or remove a majority of the board, or it is reasonable to expect they could make the entity's affairs follow their wishes. Holdings of several designated persons can be aggregated. An unlisted Lagos trading company can therefore be caught because of who stands behind it.
Reading a result: name match is not a target match
Common Nigerian names will produce hits. Section 2.2 of OFSI's guidance says a name match alone does not mean it is the same person; compare dates of birth, nationality and addresses, and treat a full match on the listed details as a likely target match. If you cannot rule a hit in or out, contact OFSI; for a likely target match, contact OFSI immediately and do not deal with the funds.
| Result | What it usually means | What to do |
|---|---|---|
| No hit on any name | Nothing on the list today | Keep a dated record; re-screen before large payments |
| Name hit, details differ | Probably a different person | Record why you ruled it out (date of birth, address) |
| Name hit, details unclear | Cannot tell | Pause payment and ask OFSI |
| Details match | Likely target match | Freeze, do not deal, report to OFSI |
Reporting, licences and who has extra duties
If you know or have "reasonable cause to suspect" you are dealing with a designated person, the guidance says to freeze, not deal, and report. Reports go through the GOV.UK online form for suspected breaches, with some information emailed to OFSI. Filing a suspicious activity report or telling another regulator does not meet the sanctions reporting duty.
"Relevant firms" carry a formal duty to report to OFSI as soon as practicable. They include FCA-authorised firms, money transmitters, accountants and legal advisers, estate agents, precious metals and stones dealers and cryptoasset businesses, with high value dealers, art market participants, insolvency practitioners and letting agents added from 14 May 2025. An ordinary importer is not on that list, but the prohibitions still apply to you.
OFSI can license some acts that would otherwise breach a prohibition. It does not charge for licences and cannot issue them retrospectively, so a licence must be in place before you pay.
A screening routine that fits a small importer
- Screen at onboarding, before the first purchase order, and keep a dated screenshot or export.
- Re-screen when owners, bank details or the paying party change; a request to pay a new account is also a fraud signal (see checking a Nigerian supplier before paying).
- Sign up to the sanctions email alerts and re-run your supplier list when a relevant regime changes.
- Keep screening records with your customer due diligence; the trade red flags in this guide to invoice warning signs are the other half of the check.
Where Pryme fits
A Pryme Business Account holds GBP, USD, EUR and NGN with local details for each, so paying a screened Nigerian supplier does not mean routing through an unknown agent. The Compliance agent prepares supplier checks and records them; a person approves above the ceiling you set. Payments to Nigeria go through business multicurrency accounts, and the app shows the rate and the fee before you approve. Outside Nigeria, Pryme's activities are carried out through regulated partners.
Questions people ask
Is Nigeria under UK sanctions?
The UK Sanctions List is organised by regime and by designated person, entity or ship. Screening a Nigerian counterparty is about the specific people and companies involved, not the country as a whole; search the names on the list itself.
Can I still use the OFSI Consolidated List?
No. It closed on 28 January 2026 and is no longer updated. The UK Sanctions List is the only source of UK designations.
What if my Nigerian supplier's director has the same name as someone listed?
Compare date of birth, nationality and address. A name match alone is not a target match. If you cannot rule it out, pause and contact OFSI.
Does an asset freeze apply to companies the person owns?
Yes. OFSI's guidance applies the freeze to entities a designated person owns or controls, including through holdings of more than 50% or the power to appoint most of the board.
Sources
- GOV.UK (FCDO): The UK Sanctions List (updated 16 Oct 2026) · accessed Oct 2026
- OFSI on GOV.UK: UK financial sanctions general guidance (updated 12 May 2026) · accessed Oct 2026
This article is general information, not financial, legal or tax advice. Products described are provided under the terms on this site and are subject to regulation and eligibility.