U.S. and UK Economic Sanctions Authorities - A Comparative Overview (June 23, 2026)

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (251 words)

Notes:

1) This document is similar to the Introduction to the Office of Foreign Assets Control published shortly prior to the publication of this document, except this document is often even more elementary as it relates to OFAC, and it has the side-by-side comparison with UK sanctions. Except as described below, the document does not break new ground and is not otherwise notable as it relates to the scope and operation of OFAC’s laws or practices.

2) One aspect of the document that is notable is OFAC’s characterization of “Interpretive Guidance” from the licensing division as “formal” guidance, in contrast to “informal guidance” provided by the Compliance Hotline. We are not aware of this explicit “formal”/”informal” distinction made anywhere else, though it is not inconsistent with OFAC’s characterizations of the two.

3) OFAC reiterates/refreshes its guidance...

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U.S. and UK Economic Sanctions Authorities - A Comparative Overview (June 23, 2026)

TURBOFAC Commentary (251 words)