The Treasury’s Office of Foreign Assets Control (OFAC) published A Framework for OFAC Compliance Commitments last week to provide guidance on the essential components of an effective sanctions compliance program (SCP).
A recent CUNA CompBlog post delves into the framework.
Essential SCP components include:
- Management commitment;
- Risk assessment;
- Internal controls;
- Testing and auditing; and
The 12-page document outlines how OFAC may incorporate these components into its evaluation of apparent violations and resolution of investigations resulting in settlements.
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