The Department of the Treasury's Office of Foreign Assets Control (OFAC) has published its Memorandum of Understanding with the United Kingdom's Office of Financial Sanctions Implementation (OFSI).
The Memorandum of Understanding (MoU) outlines a framework for collaboration to strengthen their shared mission of enforcing and promoting compliance with economic and trade sanctions. Key elements include:
.Purpose and Cooperation:
•The Participants aim to collaborate, share information, and coordinate efforts in enforcing sanctions within their respective jurisdictions.
•Cooperation encompasses information sharing, coordinated investigations, personnel training, economic analysis, and other mutually developed practical arrangements.
.Information Sharing:
•Information sharing is governed by applicable laws, with Participants retaining discretion to withhold information if disclosure would violate laws, harm investigations, affect national interests, or be deemed inappropriate.
•Requests and information exchanges must be documented in compliance with recordkeeping requirements.
Safeguards:
•The Participants are committed to handling personal data breaches in a compliant and expeditious manner.
•Re-dissemination of shared information requires appropriate consent and adherence to agreed protocols.
.Discretion in Refusal:
•Participants may decline to share information if doing so would violate laws, compromise investigations, harm national interests, or conflict with alternative sharing mechanisms.
The MoU reflects a shared intent to enhance regulatory enforcement and collaboration while respecting jurisdictional sovereignty and legal constraints.
In a November 2024 joint post regarding the collaboration, Giles Thomson, Director Economic Crime & Sanctions, OFSI and Lisa Palluconi, Acting Director, OFAC stated "we remain committed to designing, communicating, and implementing new sanctions in close coordination with each other, as well as with other key allies and partners. It is imperative that we collaborate with each other and industry to ensure sanctions are implemented as effectively as possible."
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