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.

Jaclyn Jaeger is a freelance contributor to Compliance Week after working for the company for 15 years. She writes on a wide variety of topics, including ethics and compliance, risk management, legal,...