Context
In January 2026, the UK’s Office of Financial Sanctions Implementation (OFSI) and the U.S. Office of Foreign Assets Control (OFAC) met in London for the latest in-person exchange under the UK-US Enhanced Partnership. Today, the OFSI and OFAC are jointly publishing new joint guidance to help businesses navigate important differences and similarities between the UK and U.S. sanctions regimes. The guidance provides a comparative overview, and compares important aspects of the U.S. and UK sanctions regimes, including sanctions lists, licences, record keeping and reporting requirements.
Key points to note and next actions
As the Enhanced Partnership enters its fifth year, the core mission remains clear: sanctions should deliver maximum impact, minimise unintended consequences and be easy to understand and implement, whilst deterring non-compliance.
OFAC and OFSI have worked together to:
- evaluate their parallel mechanisms to enable them to rapidly increase sanctions pressure;
- harness lessons learned from the novel restrictions developed as part of their coordinated response to Russia’s illegal invasion of Ukraine to apply to other scenarios;
- identify typologies and economic impact of sanctions targets to more effectively disrupt concerning behaviour, such as in relation to the shadow fleet;
- review and enhance processes necessary to dismantle sanctions regimes in a structured way, such as in Syria; and
- translate the lessons learned and insights from their global sanctions regimes, such as counternarcotics or illegal migration, to produce new tools and resources that can be applied across shared sanctions regimes.