US and UK Release Joint Sanctions Guidance as OFAC Expands Russia, Cuba and Iran Measures

The U.S. Office of Foreign Assets Control (OFAC) and the United Kingdom’s Office of Financial Sanctions Implementation (OFSI) have published their first side‑by‑side comparison of the two countries’ financial sanctions regimes. The guidance, part of the OFAC‑OFSI Enhanced Partnership launched in 2022, outlines similarities and key legal differences, notably the U.S. 50% ownership rule versus the UK’s separate approach. It is intended to help multinational firms navigate compliance but does not create a unified rulebook.

In parallel, OFAC announced several new sanctions actions: General License 131H authorises limited transactions linked to Lukoil International GmbH’s contingent contracts; FAQs on Russia and Venezuela were amended; the State Department expanded Cuba sanctions, designating nine entities and two individuals, while OFAC issued Cuba General Licenses 2‑4 to permit certain wind‑down activities. Additionally, OFAC targeted a network linked to Iranian businessman Babak Zanjani, designating four individuals and nine entities involved in financial‑services and digital‑asset operations.

These steps reflect coordinated U.S. and allied efforts to tighten financial controls on Russia, Venezuela, Cuba and Iran‑connected actors.