Recently, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published “A Framework for OFAC Compliance Commitments” to help organizations take a risk-based approach to developing a sanctions compliance program (SCP).
Entities like the Wolfsberg Group and the Financial Crimes Enforcement Network (FinCEN) have released similar guidance in the past, but issuing an official SCP framework is new territory for OFAC. OFAC’s motivation for publishing the framework is unclear, but it could be the seemingly record-setting pace for enforcement cases in 2019. OFAC has levied more than $1.2 billion in civil penalties against businesses so far this year.
It’s important to remember that a one-size-fits-all SCP doesn’t exist. Each program will vary depending on several factors, including an organization’s size, line of business, geographic location and customers. However, the OFAC framework recommends every SCP should focus on these five essential components of compliance:
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