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    OFAC vs OFSI

    How the US Office of Foreign Assets Control and the UK Office of Financial Sanctions Implementation differ — and why most regulated businesses need to screen against both.
    Jurisdiction

    OFAC

    United States — administered by the US Department of the Treasury.

    OFSI

    United Kingdom — part of HM Treasury.

    Primary List

    OFAC

    Specially Designated Nationals and Blocked Persons List (SDN), plus sectoral lists (SSI, NS-MBS, FSE, etc.).

    OFSI

    UK Consolidated List of Financial Sanctions Targets.

    Legal Basis

    OFAC

    International Emergency Economic Powers Act (IEEPA), Trading With The Enemy Act, and country-specific sanctions statutes.

    OFSI

    Sanctions and Anti-Money Laundering Act 2018 (SAMLA) and country-specific regulations.

    Extraterritorial Reach

    OFAC

    Broad: any USD-denominated transaction or US-person involvement triggers OFAC jurisdiction.

    OFSI

    Limited to UK persons, UK-incorporated entities, and conduct in the UK.

    Update Frequency

    OFAC

    Updates published as designations occur — often multiple times per week.

    OFSI

    Updates published as designations occur, typically weekly.

    Maximum Civil Penalty

    OFAC

    Per-violation civil penalties indexed annually; criminal penalties up to USD 1m and 20 years imprisonment.

    OFSI

    Civil monetary penalties up to GBP 1 million or 50% of the value of the breach (whichever is greater).

    Licensing Regime

    OFAC

    General and specific licences issued for permitted transactions.

    OFSI

    General and specific licences issued under HM Treasury authority.

    Reporting Obligation

    OFAC

    Blocked / rejected transactions must be reported to OFAC within 10 business days.

    OFSI

    Frozen assets and breaches must be reported to OFSI as soon as practicable.

    Practical implication for non-financial institutions

    For most UK-regulated non-financial institutions (law firms, estate agents, accountants, TCSPs, dealers in high-value goods), screening against the UK Sanctions List is the regulatory minimum. However, most modern client portfolios touch USD payments, US-incorporated entities, or US-resident principals — pulling them into OFAC's extraterritorial reach. The pragmatic answer is to screen against both lists in a single check, which is what FirmScreen does by default.

    FAQ

    Questions firms ask

    Common questions about OFAC and OFSI.

    Still have a question?
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    1. If your business has any UK or US nexus — UK-incorporated entity, US-person staff, USD-denominated transactions, or customers connected to either jurisdiction — you should screen against both. Designations diverge: a person may be sanctioned in the UK and not the US, or vice versa.

    2. OFAC has broad extraterritorial reach driven by USD clearing and US-person involvement, with very large civil and criminal penalties. OFSI applies to UK persons and UK conduct, with a maximum civil penalty of GBP 1 million or 50% of the breach value, and operates a public ‘naming and shaming’ regime alongside fines.

    3. Routinely. Post-Brexit, the UK manages its own designation process under SAMLA 2018, and the EU operates a third regime. Russia, Iran, and counter-terrorism designations are the most common areas of divergence between OFAC and OFSI.

    4. Yes. FirmScreen screens against the OFAC SDN List, the UK Sanctions List, the EU Financial Sanctions File and the UN Security Council Consolidated List in a single check. See the Sanctions Lists page for full coverage details.

    Screen both regimes in one check

    FirmScreen covers OFAC SDN, UK OFSI, EU Consolidated, and UN Security Council in a single screening operation.

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