On May 2, 2019, the U.S. Department of the Treasury's Office
of Foreign Assets Control released "A Framework for OFAC Compliance
Commitments", providing general guidance on the elements
OFAC considers to compose an effective sanctions compliance
program.
Broadly, the framework endorses a risk-based approach to
compliance (recognizing that no two compliance programs will be
identical) and the need for a formal SCP that includes five
essential components: management commitment, risk assessment,
internal controls, testing and auditing, and training. The
Framework is not a regulatory requirement, nor does it prescribe
specific controls; rather, it indicates the elements that OFAC will
look for in evaluating a company's compliance efforts in the
context of any enforcement action.
