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US, UK Say They Set Foundation for Sanctions Coordination for 'Years to Come'

U.S. and U.K. officials over the past year continued to build on a partnership between their two leading sanctions agencies, including by sharing information about national security threats and ways the agencies can modernize their approaches to licensing and enforcement, they said in a joint statement released Nov. 19.

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The U.S. Office of Foreign Assets Control and the U.K.’s Office of Financial Sanctions Implementation began an “enhanced partnership” in 2022, which has included swapping officials as part of an employee embed program, working together on sanctions guidance and better harmonizing their designations (see 2311170038). The statement this week highlighted the progress OFAC and OFSI said they have made in the second year since they formed the partnership, and it came after leaders from both agencies met in Washington last month for a “technical exchange.”

The agencies didn’t explicitly say whether the partnership would continue under the incoming Trump administration, but they said they have “set the stage for continued collaboration and success in the years to come.”

OFAC and OFSI said they made “significant progress” this year on issuing better guidance to industry, pointing to OFAC’s new approach to archiving FAQs (see 2408020041) and similar efforts by OFSI to provide answers to common questions from industry (see 2408160003">2408160003, 2407160039 and 2411130032). The two agencies also said they signed a memorandum of understanding that will improve their “ability to collaborate and share information, further fortifying our coordinated efforts in implementing and enforcing sanctions.”

That has included sharing information about Russia-related sanctions, including restrictions on the trade of certain Russian metals.

"While operational functions have historically been at the forefront of our information-sharing,” the agencies said, “we look forward to collaborating more closely in sharing our analysis to support our future actions and any mitigation measures.”

Officials also discussed ways they can modernize their agencies, including through improved software that helps “support our licensing and enforcement functions, and the use of new technologies as we look to stay at the cutting-edge of implementation.” OFAC pointed to some of its recent modernization efforts, which has included a new requirement for filers of blocked property to submit those documents electronically instead of through mail (see 2405080023) and the May launch of its Sanctions List Service (see 2405060043).

The U.S. and U.K. “reflected on how OFAC’s recent announcement of its modernization efforts could be adapted and replicated within the UK to ensure delivery of timely and effective responses to those seeking to comply with our regulations.”