In October 2024, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the United Kingdom’s Office of Financial Sanctions Implementation (“OFSI”) celebrated the second anniversary of their Enhanced Partnership. This collaboration, initiated in response to the increasingly complex geopolitical landscape, aims to bolster the effectiveness of sanctions as a global tool for national security. Over the past two years, OFAC and OFSI have worked closely to coordinate their sanctions regimes, share critical information, and engage with the private sector to ensure robust compliance and enforcement.
The Enhanced Partnership has achieved several significant milestones this year. One of the key achievements is the signing of a Memorandum of Understanding (“MOU”) to enhance information sharing between the two authorities. This MOU facilitates the timely exchange of data and analysis, which is crucial for the effective implementation of sanctions.
Additionally, the Enhanced Partnership has focused on joint outreach efforts with the private sector, including meetings with key stakeholders, such as the Bank Policy Institute, to discuss compliance challenges and opportunities for alignment.
Looking ahead, the partnership is expected to continue evolving, with a focus on leveraging new technologies and enhancing collaboration at all levels. OFAC and OFSI have discussed modernizing their operations by updating software to support licensing and enforcement functions and using new technologies to stay at the cutting edge of implementation. As part of this, OFAC recently announced that it is updating its FAQs on general sanctions questions and issues. The Enhanced Partnership has reflected on how this, and other efforts to modernize, can be replicated in the UK.
Companies with footprints or supply chains in the US and/or UK should be aware of the impacts of this partnership on corporate compliance expectations in both countries. This OFAC-OFSI cooperation is just one of many examples of the increased cross-border efforts that have been catalyzing the broader heightened sanctions compliance and enforcement environment. Our US, UK and global trade team and our Global Sanctions Investigations Group provide our clients with holistic advice on how to manage and mitigate these risks.
