OFAC and OFSI publish joint guidance comparing US and UK sanctions

In brief

• What: OFAC and the UK’s OFSI published a joint comparative document (the OFAC–OFSI Comparative Overview) setting key elements of the US and UK financial sanctions regimes side by side.
• Who issues it: OFAC (US Department of the Treasury) and OFSI (HM Treasury, Office of Financial Sanctions Implementation).
• Status / timing: published 23 June 2026; the guidance applies from the date of publication (no formal entry-into-force date).

What changes

On 23 June 2026 OFAC and OFSI published the OFAC–OFSI Comparative Overview — a joint document comparing key elements of the US and UK financial sanctions regimes. It covers, among others, sanctions lists, available licenses (authorizations), and recordkeeping and reporting requirements, highlighting similarities and differences between the two systems. The document is a general overview — OFAC and OFSI recommend consulting the detailed guidance and regulations relevant to a specific context. On the same day OFAC issued TCO General License 2 authorizing the wind down of transactions involving CCU Commercial Bank Plc., and updated its SDN List: new designations relate to transnational criminal organization activity (Prince Group) and Cuba; several Russia-EO14024 entries were also removed.

Who is affected

The document is aimed at financial institutions and compliance entities operating cross-border — particularly those subject to both regimes simultaneously: banks, payment institutions, and sanctions teams operating in both US and UK jurisdiction. The intended audience is primarily the financial sector with exposure to both markets, not Polish businesses in general.

What it means for non-financial firms

For a typical Polish non-financial firm — a travel agency, a real-estate broker, an online shop or an insurance broker — this document imposes no new obligations. It is an intra-sector change, tailored to financial institutions exposed to both transatlantic markets.

Where the guidance may have indirect relevance: if your firm works with counterparties in the US or UK and uses banks or payment partners there, it is worth knowing that the US sanctions regime (OFAC’s SDN List) and the UK one (the OFSI list) are two separate systems with different lists, licenses and reporting requirements. The OFAC–OFSI Comparative Overview shows exactly these differences — which can be useful background for law firms and e-commerce companies settling transactions with Anglo-American entities.

Who should pay attention: law firms serving clients with transatlantic exposure, and larger e-commerce platforms settling transactions in USD or GBP. Other sectors: no real impact on current obligations. More on which sanctions lists apply in Poland and the EU — in a separate article.

What’s next

If you operate cross-border in US or UK jurisdiction, it is worth reviewing the full text of the document directly on the OFAC site. For firms operating solely in the Polish/EU market: monitor the SDN and OFSI lists as a complement to your sanction screening obligation, but this publication does not change your current obligations. The full OFAC actions of 23 June are available at: OFAC Recent Actions — 23 June 2026.