OFAC Issues ‘A Framework for OFAC Compliance Commitments’

Posted by Matt Schmitt on 5/3/19 5:00 PM

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:

  • Management commitment;

  • Risk assessment;

  • Internal controls;

  • Testing and auditing; and

  • 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:


The framework for OFAC compliance commitments may be found here:


Topics: OFAC, Compliance, Guidance