US & UK Sanctions Authorities Release Joint Comparative Guidance

On 23 June 2026, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) and HM Treasury’s Office of Financial Sanctions Implementation (OFSI) issued joint guidance providing a comparative overview of the US and UK economic sanctions regimes.

OFAC and OFSI published the Guidance in connection with the OFAC-OFSI Enhanced Partnership, which launched in 2022. It is another recent example of sanctions regulators providing summary information to support private sector stakeholders in understanding sanctions compliance. See our recent alert. 

The Guidance compares key features of the US and UK sanctions regimes, and provides baseline information regarding:

• The respective roles and responsibilities of OFAC and OFSI, and the legal frameworks under which they operate; 
• Explanations of sanctions terminology such as “SDNs” and “DPs”;
• Types of sanctions deployed in each jurisdiction, such as blocking, non-blocking and sectoral sanctions; 
• Links to the US and UK sanctions lists and search tools;
• Links to certain sanctions programs administered by the authorities; 
• A summary of the jurisdictional scope of the sanctions; 
• The forms permitted activity may take, such as exempt or excepted activity;
• Comment on recordkeeping and reporting; and 
• Licensing.

The Guidance contains a wide selection of links to guidance under both regimes, and highlights some of the similarities and differences between the regimes in relation to the enforcement approaches (including civil penalty powers) and frameworks for assessing violations and breaches, strict liability standards, voluntary disclosure policies and limitations periods. For example, the Guidance notes that OFSI “may” consider a qualifying voluntary disclosure to be a mitigating factor, while OFAC considers a qualifying voluntary self-disclosure (as described in OFAC’s Economic Sanctions Enforcement Guidelines) to be a mitigating factor (see, e.g., Appendix A to 31 CFR Part 501 at I.I, III.G.). The Guidance also reminds its readers that where a qualifying voluntary self-disclosure is made, “OFAC may apply a 50 percent reduction to the base amount of the proposed civil penalty,” while “OFSI may apply up to a 30 percent reduction in the final monetary penalty amount.”  

The Guidance concludes with a closer look at the complexities inherent in the regimes’ approaches to the application of sanctions to non-listed entities, and the related concepts of ownership and control. 

Notably, the Guidance does not refer to the role of the Office of Trade Sanctions Implementation (OTSI), whose enforcement powers came into effect on 10 October 2024¹ to strengthen the UK’s implementation and enforcement of trade sanctions. OTSI’s main functions include engagement and guidance, licensing and enforcement in relation to UK trade sanctions. As such, OTSI works closely with other government bodies on sanctions enforcement, including OFSI and has recently expanded its licensing remit². While not set out in the Guidance, OTSI has a significant role and responsibility as a UK sanctions regulator, including with respect to wide-spanning impact of trade sanctions and potential reporting obligations.  

As sanctions laws continue to evolve, the Guidance provides timely information to assist compliance professionals and other stakeholders as they attempt to understand their obligations in a complex and rapidly changing legal environment.  It will be interesting to follow how OTSI and OFSI collaborate to communicate UK sanctions compliance expectations and how, in co-operation with OFAC, this may lead to further guidance to assist sanctions compliance across both UK and US regimes. 

Read the joint guidance here.

¹The regulatory framework for OTSI is provided in the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 

²Expanding OTSI’s Licensing Remit  – Office of Trade Sanctions Implementation