OFAC and OFSI publish guide comparing US and UK sanctions rules

WASHINGTON, June 23, 2026 — The US Treasury’s Office of Foreign Assets Control and the UK Office of Financial Sanctions Implementation have published a 13-page comparative guide aimed at helping businesses understand how the two sanctions systems align and where they differ. The document says it covers core topics including sanctions lists, available licenses, recordkeeping and reporting requirements.

The guide underscores that both systems broadly require domestic persons to comply, but it highlights a key structural difference in reach. OFAC says all US persons, including US entities’ foreign branches, must comply, and some non-US persons can also face liability for causing violations or evasion. OFSI says all UK persons must comply and notes that non-UK persons can also be caught where there is a UK nexus.

It also draws a clear distinction in terminology and mechanics. OFAC refers to sanctions programs, blocked persons and blocked property, while OFSI refers to sanctions regimes, designated persons and asset freezes. The guide says OFAC can impose both blocking and non-blocking sanctions, as well as secondary sanctions and broad jurisdiction-based restrictions, while OFSI does not have broad jurisdiction-based sanctions of that kind.

For compliance teams, some of the most practical differences are in reporting and recordkeeping. OFAC says persons subject to its regulations generally must keep full and accurate records for at least 10 years and report blocked, unblocked or transferred property within 10 business days. OFSI says UK law does not set a single sanctions-specific retention period in the same way, but relevant records must be retained under other UK financial recordkeeping rules. The guide also says OFSI does not have a reporting requirement for rejecting a prohibited transaction, unlike OFAC.

On licensing, both agencies say permitted activity may rest on exemptions or exceptions and on general or specific licenses. But the guide notes that OFSI general licenses can require prior notification, recordkeeping or reporting, while both agencies warn that individual licenses can carry additional conditions that firms must review closely.

The publication forms part of the OFAC-OFSI enhanced partnership launched in October 2022 and appears designed to give multinational companies a single reference point as Washington and London deepen sanctions coordination.