Clients dealing with international sanctions often need to understand which authority is relevant to their situation. Office of Foreign Assets Control (“OFAC”) is the US sanctions authority, while Office of Financial Sanctions Implementation (“OFSI”) is the UK body responsible for financial sanctions implementation and enforcement.
The OFAC administers and enforces US economic and trade sanctions. Its rules may affect US persons, US-dollar transactions, US-origin goods, dealings with blocked persons and other situations with a US nexus.
The difference between OFSI and OFAC legal advice is important because the two authorities operate under different legal systems, licensing processes, enforcement approaches and sanctions programmes. A matter may involve one regime, or both, depending on the parties, currency, location, ownership structure and transaction pathway.
We advise clients on whether OFSI, OFAC or both authorities may be relevant and we help assess the practical steps required. We work in this area and are ready to cooperate with clients who need joined-up sanctions advice across UK and US regimes.
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