US and UK Issue Sanctions Guidance

By Heather Phillips 04/08/2026 2 min read 24 views

The Office of Foreign Assets Control (OFAC) and the Office of Financial Sanctions Implementation (OFSI) have published joint guidance on US and UK sanctions. OFAC administers and implements numerous sanctions programs in accordance with various US legal authorities, including statutes, executive orders, and regulations.

Sanctions Programs

OFAC’s sanctions programs include list-based blocking sanctions, list-based non-blocking sanctions, sector-based sanctions, government blocking, jurisdiction-based sanctions, and secondary sanctions. OFSI, on the other hand, administers multiple sanctions regimes in accordance with UK legal authorities, including primary and secondary legislations and laws implementing UN Security Council Resolutions.

OFSI’s sanctions programs include list-based financial sanctions, sectoral sanctions, and directions. Unlike OFAC, OFSI does not impose blanket or country-based sanctions. Instead, it maintains the UK Sanctions List for persons financially sanctioned under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA).

Jurisdiction and Compliance

OFAC has jurisdiction over US persons, which include all US citizens and permanent residents, as well as individuals and entities within the US. OFAC sanctions also apply extraterritorially, prohibiting non-US persons from causing or conspiring to cause US persons to violate US sanctions. OFSI, on the other hand, has jurisdiction over all UK persons, regardless of their location, as well as individuals and entities within the UK.

Both OFAC and OFSI require persons subject to their jurisdiction to comply with their respective sanctions programs. This includes keeping records of sanctioned transactions and reporting certain activities to the relevant authorities. OFAC requires US persons to keep records for at least 10 years.

Both OFAC and OFSI play critical roles in enforcing their respective countries’ sanctions programs, and their cooperation is essential to effectively implementing these programs.

Enforcement and Penalties

OFAC and OFSI both have the authority to impose civil monetary penalties for sanctions violations. OFAC applies a strict liability legal standard, meaning that a person subject to US jurisdiction may be held civilly liable even if they did not have knowledge that they violated OFAC sanctions. OFSI may impose civil penalties based on a strict liability legal standard for sanctions breaches occurring after June 15, 2022.

Both OFAC and OFSI encourage voluntary disclosure of sanctions violations, with OFAC offering a potential 50 percent reduction to any civil monetary penalty and OFSI offering a possible 30 percent reduction. The factors considered in determining the appropriate administrative action include the nature of the violation, the harm caused, and the person’s cooperation with the authorities.

US persons must comply with OFAC regulations.

For more information on US sanctions, visit the US Department of the Treasury’s website. The UK Government’s website provides information on UK sanctions and sanctions implementation.