On October 17, 2022, the US and UK announced plans to enhance their partnership by increasing their cooperation and collaboration in the implementation of financial sanctions. Following a multi-day technical exchange in London between their two offices, Andrea Gacki, the Director of the US Office of Foreign Assets Control, and Giles Tomson, Director of the Office of Financial Sanctions Implementation, released a statement announcing their commitment to a close working relationship that will bring significant benefits to their organizations for years to come.
In their statement, the Directors explained that OFAC and OFSI, two of the world’s largest financial sanctions implementation authorities, have much in common “with similar corresponding functions and tools, such as the ability to issue general licenses and civil monetary penalties with comparable legal thresholds.” Over the coming months, the organizations will deepen their partnership by exchanging best practices, identifying opportunities to pool expert resources, addressing common challenges, and exploring ways in which they can align the way they implement sanctions. They also plan to collaborate on the publication of joint products or guidance for stakeholders in an effort to improve sanctions compliance. The Directors revealed that OFAC and OFSI have already started collaborating on ways to improve information sharing, address cyber threats and the misuse of virtual assets, and prevent financial sanctions from negatively affecting humanitarian trade.
The Directors also agree that financial sanctions work best when implemented multilaterally – a practice that not only maximizes the impact of sanctions but also minimizes unintended consequences and eases the compliance burden on businesses. For this reason, throughout the Russia/Ukraine crisis, OFAC and OFSI have made an effort to coordinate with one another behind the scenes and with key allies and partners before imposing financial sanctions. As their partnership grows and collaboration improves, OFAC and OFSI hope to improve financial sanctions imposed in response to Russia’s invasion of Ukraine and extend these benefits to other common sanctions regimes.