OFAC and OFSI publish a joint US and UK sanctions comparative overview

What happened

On 23 June 2026, OFAC (the US Office of Foreign Assets Control) and OFSI (the UK Office of Financial Sanctions Implementation, part of HM Treasury) jointly published “The U.S. and UK Economic Sanctions Authorities: A Comparative Overview.” It is guidance, not a rule change or a new obligation.

The overview compares the US and UK sanctions regimes, setting out similarities and differences across sanctions lists, licences, and recordkeeping and reporting requirements. It outlines the roles of both authorities, the legal frameworks that underpin sanctions, the types of sanctions measures available, and the scope of each authority’s jurisdiction.

The document also highlights where the two regimes part ways. According to the publication, those differences run through terminology, sanctions structures, the lists themselves, and the treatment of sanctioned persons and assets.

The overview sits within the OFAC-OFSI Enhanced Partnership. It follows a week-long in-person strategic dialogue the two authorities held in London in January 2026 on how each uses its powers to meet foreign policy and national security objectives.

Why it matters

Read as analysis, the two authorities have now set their regimes side by side in one jointly authored document. Firms running dual US and UK programs have long had to reconcile the two regimes from separate primary sources. A jointly authored comparison narrows that gap.

The value is in the divergences the overview names. Terminology, list structures, and the treatment of sanctioned persons and assets are exactly the points where a single screening or licensing assumption can quietly fail in one jurisdiction while holding in the other. A control calibrated to one regime is not automatically sound under the other.

This is guidance, so it changes no law and imposes no deadline. It does give sanctions and legal teams a shared reference point that an examiner or counterparty is likely to recognise.

Practitioner angle

Use the overview as a reconciliation tool across your dual-regime controls rather than as background reading.

• Map your US and UK sanctions screening against the list structures the overview describes, and confirm your screening covers the right lists for each regime.
• Compare your licensing workflows to both authorities’ approaches, and flag any general or specific licence assumption that holds in one jurisdiction but not the other.
• Check your recordkeeping and reporting against both sets of requirements, and note where one process can satisfy both and where it cannot.
• Reconcile terminology in your policies and procedures so that a term carrying one meaning under one regime is not applied loosely to the other.
• Pay close attention to the treatment of sanctioned persons and assets, where divergence in scope can change how you freeze, report, or release.

Brief your sanctions and legal teams that carry dual-regime obligations, and walk them through the divergences the overview identifies. The single most important action: run a structured gap review of your combined US and UK sanctions controls against this overview, and document where one control serves both regimes and where each regime demands its own.