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
• Training.

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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