In a bid to strengthen sanctions enforcement, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) and the UK's Office of Financial Sanctions Implementation (OFSI) have recently signed a Memorandum of Understanding (MOU). Both authorities share a common mission to combat financial crime and ensure compliance, but they operate under distinct legal frameworks. Notably, the penalties imposed by OFSI remain significantly smaller compared to those imposed by OFAC.
It appears that OFSI is seeking to draw insights from OFAC’s approach to enhance its own enforcement strategy. This partnership could signal a tougher stance on sanctions enforcement from OFSI, as well as closer alignment between the US and UK sanctions regimes. However, structural challenges persist within the UK, and without enhanced coordination among UK sanctions authorities, effective enforcement will remain difficult.
John Binns, partner, and Magali Sharma, associate, explain the impact this MOU will have in LexisNexis.
This article was first written for and published by LexisNexis on 24 January 2025. To read the full article, please click here (£).
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