On 2 May 2019, the U.S. Treasury's Office of
Foreign Assets Control ("OFAC"), the agency responsible
for enforcing economic sanctions, published "A Framework for OFAC Compliance
Commitments" (the "Framework") which
outlines five components OFAC considers to be essential for an
effective risk-based sanctions compliance program. OFAC also
highlights "root causes" of sanctions violations in the
Framework. The Framework offers private equity and other fund
managers a detailed insight into OFAC's expectations with
respect to an organization's sanctions compliance program for
the first time.
What does this mean for private equity fund managers?
The Framework is particularly relevant following the U.S.
Government's escalation of U.S. sanctions around the world,
such as its recent re-imposition of sanctions against Iran and
Cuba.
