OFSI and OFAC have published new joint guidance comparing the UK and US sanctions regimes, giving businesses a useful side-by-side overview of where the two systems align and where they differ.
The publication follows a January 2026 meeting in London between the UK’s Office of Financial Sanctions Implementation and the U.S. Office of Foreign Assets Control, held under the UK-US Enhanced Partnership. The guidance reflects that ongoing cooperation and is intended to help businesses understand their obligations where they may be exposed to both UK and US sanctions rules.
This is not a new sanctions regime or a change in the law. But it is an important practical resource for compliance teams, particularly those working across multiple jurisdictions, using global screening systems or dealing with transactions that may involve UK or US touchpoints.
No new rules, but part of a bigger coordination effort
The wider aim is also important. Sanctions are most effective when major jurisdictions work together. If the UK and US regimes are easier to understand side by side, businesses are better placed to implement them consistently, and sanctioned individuals or entities have fewer opportunities to exploit gaps between systems.
For multinational financial institutions and other organisations with cross-border exposure, that matters. Sanctions programmes are becoming more interconnected, and compliance teams increasingly need to understand how different regimes interact in practice. The guidance is therefore not just a technical comparison. It is part of a broader push towards clearer, more coordinated sanctions compliance.
Where UK and US sanctions rules can diverge
For businesses, the practical challenge is that sanctions compliance is increasingly international. A business may be based in the UK, but still face US sanctions exposure through US dollar transactions, US persons, US suppliers, US technology or activity that passes through the United States.
At the same time, non-UK businesses can be caught by UK sanctions where there is a UK nexus. That might include activity taking place in the UK, involving UK persons, or otherwise falling within UK jurisdiction.
This means organisations cannot assume that one sanctions process will automatically satisfy both regimes. The UK and US systems are closely aligned in many areas, but they are not identical. The value of the guidance is that it highlights those similarities and differences in one place, giving compliance teams a clearer basis for reviewing their own sanctions controls.
What does the new guidance cover?
The joint guidance compares a number of core areas that businesses need to understand.
Sanctions lists
The guidance explains the different sanctions lists used by OFAC and the UK.
OFAC maintains the Specially Designated Nationals and Blocked Persons List, as well as several non-SDN sanctions lists. In the UK, the UK Sanctions List is maintained by the Foreign, Commonwealth and Development Office, while OFSI implements financial sanctions against those listed.
For businesses, the practical point is simple: screening needs to be clear about which lists are being checked, how often checks take place and what happens when there is a potential match.
Jurisdiction
The guidance also highlights who needs to comply.
US sanctions generally apply to US persons, including US citizens and permanent residents wherever they are located, entities in the United States and US-incorporated entities and their foreign branches. Transactions that take place in or transit through the United States can also fall within scope.
UK sanctions generally apply to UK persons wherever they are located, persons and entities within the UK and legal entities incorporated or constituted under UK law and their foreign branches. Activity by non-UK persons can also be caught where there is a UK nexus.
This is one of the most important parts of the guidance for multinational organisations. Compliance teams need to understand not only who they are dealing with, but where activity takes place, which currencies are involved, which systems are used and whether any UK or US connection exists.
Blocking, freezing and rejected transactions
The guidance compares how the two regimes treat prohibited activity.
Under OFAC rules, blocking sanctions require US persons to block property and report that action to OFAC. In some cases, a US financial institution may need to reject a prohibited transaction and report that rejection.
Under UK sanctions, an asset freeze prohibits dealing with a designated person’s funds or economic resources. UK persons holding those assets must freeze them and report that action to OFSI. The guidance also notes that OFSI does not have a reporting requirement for rejecting a prohibited transaction.
That distinction matters for internal procedures. Staff need to know when to freeze, when to block, when to reject, when to report and who inside the organisation should be involved.
Licences
Both regimes allow certain activity through general and specific licences.
The guidance explains that general licences are self-executing, meaning a person can rely on them without applying for a specific licence, provided the activity meets the terms and conditions. However, those terms still matter. OFSI general licences may require notification before use, recordkeeping or reporting.
This is a common area of risk. A licence should not be treated as a blanket permission. Organisations need to check the wording, confirm the activity fits, keep evidence and monitor any reporting requirements.
Recordkeeping and reporting
The guidance also compares recordkeeping and reporting obligations.
OFAC generally requires records of transactions subject to OFAC sanctions regulations to be kept for at least 10 years. UK financial sanctions legislation does not specify a single sanctions-related retention period in the same way, but relevant records must still be retained in line with other UK financial recordkeeping requirements.
The annual reporting deadlines also differ. OFAC’s Annual Report of Blocked Property must be filed by 30 September, covering blocked property held as of 30 June. OFSI’s Annual Frozen Asset Review must be filed by 30 November, covering assets held as of 30 September.
For compliance teams, this reinforces the need for clear documentation. It is not enough to screen once and move on. Organisations need a record of decisions, escalations, freezes, reports, licences and any follow-up action taken.
Can your controls handle both regimes?
The guidance is a useful prompt to review sanctions controls against both UK and US expectations.
Businesses should check whether their sanctions screening, escalation and reporting procedures clearly distinguish between OFSI and OFAC requirements. They should also review whether staff understand what to do when a potential match is found, when a transaction should be stopped or escalated, and when a licence may apply.
For multinational organisations, the biggest risk is assuming that UK and US sanctions rules work in exactly the same way. The new guidance makes clear that there are strong similarities, but also important practical differences.
Sanctions compliance is not just about having access to a screening tool. It requires staff to understand risk, recognise red flags, follow escalation procedures and keep proper records. The new OFSI and OFAC guidance gives organisations a timely opportunity to check whether their sanctions framework is still fit for purpose.
