The past year has witnessed a massive increase in
sanctions-related enforcement activity and has indeed caused a stir
in the global sanctions landscape. Under the new administration,
the US re-imposed all nuclear-related sanctions on Iran,
culminating in the largest ever single set of sanctions
designations to date.
With the heightened global regulatory environment and the
aggressive stance of enforcement agencies, it has been made rather
clear that sanctions laws can no longer be ignored. Moreover, in an
attempt to bring clarity to compliance expectations of the
sanctions regime in the US, on May 02, 2019, the Office of Foreign
Assets Control (OFAC) published the Framework for
OFAC Compliance Commitments (Framework). The
Framework sets out OFAC's key considerations for evaluating the
efficacy of a sanctions compliance programme (SCP)
and in turn determining whether mitigation of civil monetary
penalties ought to be granted.
