OFAC and OFSI Publish MOU on Sanctions Implementation and Enforcement

On January 13, 2025, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) and the United Kingdom’s Office of Financial Sanctions and Implementation of HM Treasury (OFSI) published a joint Memorandum of Understanding (the MOU) that sets forth the agencies’ intent to collaborate on sanctions implementation and enforcement. The MOU was signed on October 9, 2024, at a conference marking the two-year anniversary of the OFAC-OFSI Enhanced Partnership on sanctions.

The MOU encourages information sharing between OFAC and OFSI and establishes the terms by which the agencies may request, share (or refuse to share), and maintain information related to sanctions implementation and enforcement. Specifically, information that may be shared under the MOU includes: (1) administrative records as part of an investigation; (2) identifying information of or relating to persons involved in a suspected or actual violation; (3) transaction-related reports (e.g., blocked property reports); (4) information identified in specific license applications; (5) training materials and best practices; (6) reporting statistics and economic analysis; (7) names of persons or entities who have been or may soon be subject to administrative actions or other agency actions; and (8) other unclassified information obtained in connection with each agency’s respective responsibilities and authorities.

While the MOU does not legally require that OFAC and OFSI comply with requests for information from each other, the MOU enhances the two agencies’ commitment to collaborate and share information.

For questions about U.S. or UK sanctions, contact the authors or any of their colleagues in Arnold & Porter’s White Collar Defense & Investigations or Export Control and Sanctions practice groups.

© Arnold & Porter Kaye Scholer LLP 2025 All Rights Reserved. This Blog post is intended to be a general summary of the law and does not constitute legal advice. You should consult with counsel to determine applicable legal requirements in a specific fact situation.