A Framework for Sanctions Compliance: OFAC Sets Expectations
On May 2, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) released a “Framework for OFAC Compliance.” This is the most extensive guidance OFAC has provided to date on its expectations regarding sanctions compliance. In particular, while OFAC continues to believe that companies should apply a risk-based approach to developing, implementing, and periodically updating a “sanctions compliance program” (“SCP”), OFAC has, for the first time, outlined its views on essential components of an SCP.
OFAC recommends that companies focus on these five compliance components: (1) management commitment; (2) risk assessments; (3) internal controls; (4) testing and auditing; and (5) training.