US, UK Swapping Sanctions Officials as Part of New Employee Embed Program

The American and British agencies in charge of sanctions implementation have “worked more closely than ever” during the last year and are planning to share more data, issue additional guidance and better harmonize their sanctions measures, they said last week. They also announced a plan to embed an official within the other country’s agency to help train and learn about each side's respective sanctions procedures.

An official with the Office of Foreign Assets Control is already embedded within the U.K.’s Office of Financial Sanctions Implementation, the two agencies announced in a joint release. OFSI “plans to have an OFSI employee at OFAC soon.”

The release highlighted the progress OFAC and OFSI said they have made in the year since they began an “enhanced partnership” in October 2022. Leaders from both agencies met in London last month for a “multi-day technical exchange” to mark the anniversary.

They also said they have held a range of other meetings over the last year, scheduled joint travel to other countries to talk about Russian attempts at sanctions evasion, and have worked on joint sanctions guidance to help companies comply with their restrictions. That included a June guidance that was designed to clarify what types of humanitarian aid and transactions are authorized for Russia (see 2306280023); both agencies said they have “heard directly” from non-governmental organizations and financial institutions that the guidance was helpful.

In addition, their increased collaboration allows them to better harmonize the U.S. and U.K. sanctions programs and speak about “areas where our respective authorities may differ,” they said, such as on ownership and control and reporting requirements. The two sides said they have committed to “work more closely on these policy areas going forward” and share more data “across a range of functions to increase insights, strengthen analytical capacity to inform sanctions programme design and implementation, and identify more ways to strengthen coordination of our ongoing efforts.”