On May 2, 2019, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) published a “framework” for compliance commitments associated with U.S. economic and trade sanctions programs.
According to the framework document, OFAC “strongly encourages organizations” to have a risk-based sanctions compliance program (SCP) in place that incorporates at least the following components:
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Management commitment;
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Risk assessment;
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Internal controls;
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Testing and auditing; and
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Training.
OFAC emphasizes that the existence, nature, and adequacy of an SCP may mitigate civil monetary penalties resulting from an investigation into a sanctions violation.
The OFAC press release may be found here:
https://home.treasury.gov/news/press-releases/sm680
The framework for OFAC compliance commitments may be found here:
https://www.treasury.gov/resource-center/sanctions/Documents/framework_ofac_cc.pdf
