A Framework for OFAC Compliance Commitments

Yesterday, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published ‘A Framework for OFAC Compliance Commitments’ in order to provide organisations subject to U.S. jurisdiction, as well as foreign entities that conduct business in or with the United States or U.S. persons, or that use U.S.- origin goods or services, with a framework on the essential components of a sanctions compliance program (SCP). The document also outlines how OFAC may incorporate these components into its assessment of apparent violations and resolution of investigations resulting in settlements. OFAC strongly encourages organisations to approach sanctions compliance using a risk-based analysis by developing and updating a SCP. While each risk-based SCP will vary depending on a variety of factors –  including the company’s size and sophistication, products and services, customers and counterparties, and geographic locations – …

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