3 May 2019
Last year, OFAC signaled that it would be issuing much-anticipated guidance for companies on building sanctions compliance programs and, on May 2, 2019, OFAC delivered. "A Framework for OFAC Compliance Commitments" (the "Framework") sets forth OFAC's view of the elements of an effective compliance program. In the buildup to publishing the Framework, OFAC increasingly had included compliance-related guidance in its public settlement documents and enforcement notices, much of which is reproduced and highlighted in the Framework as "root causes" of sanctions violations.
A Framework for OFAC Compliance Commitments