OFSI vs OFAC: Dual Sanctions Screening
Importers and brokers who handle a single shipment can touch two sanctions regimes without realizing it. A payment cleared in dollars pulls in Washington; a counterparty incorporated in Leeds or a freight forwarder with a London office pulls in Whitehall. Treating UK and US screening as one undifferentiated task is how compliance gaps form. The two systems share vocabulary but diverge on legal basis, list construction, and enforcement posture.
Two regulators, two statutory roots
The US Office of Foreign Assets Control (OFAC) administers economic sanctions from inside the Treasury Department, drawing authority chiefly from the International Emergency Economic Powers Act and the Trading with the Enemy Act. The UK's Office of Financial Sanctions Implementation (OFSI), a unit of HM Treasury created in 2016, enforces UK financial sanctions from a newer foundation: the Sanctions and Anti-Money Laundering Act 2018, the framework that let Britain run an autonomous regime after leaving the EU. The practical lesson of OFSI vs OFAC is not that one is harsher, but that each reaches different conduct, and a single transaction often triggers both.
How the lists are built
OFAC publishes the Specially Designated Nationals and Blocked Persons list alongside a separate Consolidated Sanctions List for non-SDN restrictions. The UK maintains its own consolidated UK Sanctions List, organized by regime. Overlap is heavy, since most major designations appear on both, but it is never complete, and timing differs: a name added in London may lag or lead its Washington counterpart by days or weeks. Spelling, transliteration, and aliases also vary between sources, which is why screening against a current copy of both authorities' lists matters more than matching against either one alone.
Licensing and the ownership trap
Both regimes let otherwise-blocked dealings proceed under licence, through general licences that authorize a category of activity and specific licences applied for case by case, but the criteria and routes are separate, and a US licence does not cover a UK-nexus dealing. Ownership rules are where smaller firms most often stumble. OFAC's 50 Percent Rule treats any entity owned 50% or more, in aggregate, by blocked persons as blocked itself, even when that entity is not named. The UK applies its own ownership-and-control test that can capture entities through control as well as shareholding. Name-matching a counterparty is not enough when a designated party sits one layer up the chain; the work of screening ultimate beneficial owners is what closes that gap.
Why dual screening is the baseline
For an importer paying in dollars through a US correspondent bank while contracting with UK or EU parties, exposure to both regimes is the default, not the exception. Enforcement reinforces it: OFAC civil penalties operate on a strict-liability basis, and OFSI gained the power to impose monetary penalties without proving the firm knew it was dealing with a designated party after the Economic Crime (Transparency and Enforcement) Act 2022. Good intentions are no defense on either side of the Atlantic. A workable program runs dual sanctions screening against UK and US sources on a recurring basis, documents each result, and folds that record into broader counterparty due diligence. Tools such as StratoLex deliver that dual-list check as a daily refreshed signal rather than a quarterly scramble, so UK sanctions compliance and US obligations are covered in one pass.