Five ‘essential components’ of a sanctions compliance program


Chief compliance officers seeking some much-needed guidance on how to build a well-crafted sanctions compliance program would be remiss to ignore the first-ever “Framework for OFAC Compliance Commitments” published by the Department of the Treasury’s Office of Foreign Assets Control. The guidance includes a non-exhaustive list of common “root causes” of sanctions violations identified during the investigative process and in the context of recent enforcement actions.

“OFAC developed this framework in our continuing effort to strengthen sanctions compliance practices across the board,” said OFAC Director Andrea Gacki. “This underlines our commitment to engage with the private sector to further promote understanding of, and compliance with, sanctions requirements.”

The 12-page sanctions compliance framework, published May 2, applies not just to U.S. companies, but also to companies that may find themselves subject to U.S. sanctions laws—such as foreign entities that conduct business in or with the United States, those that employ U.S. citizens, or that use U.S.-origin goods or services.

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