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ARTICLE · 22 JANUARY 2025

OFAC And OFSI Publish MOU On Sanctions Implementation And Enforcement

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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...

GlobalInternational Law
Daniel M. Elsen-Rooney
Daniel M. Elsen-Rooney
Junghyun Baek
Junghyun Baek
Trevor G. Schmitt
Trevor G. Schmitt
John Barker
John Barker
Soo-Mi Rhee
Soo-Mi Rhee
Baruch Weiss
Baruch Weiss
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Kathleen Harris
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Nicholas Townsend
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Tal R. Machnes
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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

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