Sanctions Enforcement: MOU Between OFSI And OFAC Boosts Information Sharing

On January 13, 2025, the UK's Office of Financial Sanctions Implementation (OFSI) and U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) published a memorandum of understanding (the MOU).

Although only just released, the MOU was signed in October 2024, with the aim of facilitating the exchange of information between the two authorities on the implementation and enforcement of sanctions. As summarized below, the MOU contains high-level provisions designed to facilitate and guide OFSI and OFAC's information sharing approach going forward.

• Information – The type of shareable information under the MOU is broad and includes documents retained as part of an investigation; names and identifying information related to persons involved in suspected/actual sanctions violations; transaction-related reporting, such as reports made under a license; reporting statistics and economic analysis; and best practices related to business processes, work