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ARTICLE · 19 JUNE 2019

OFAC Outlines Expectations For Global Sanctions Compliance

Hogan Lovells
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On 2 May 2019 the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued "A Framework for OFAC Compliance Commitments" (the framework)

United StatesInternational Law
Aleksandar Dukic
Aleksandar Dukic
Ajay Kuntamukkala
Ajay Kuntamukkala
Beth Peters
Beth Peters
Stephen Propst
Stephen Propst
Anthony Capobianco
Anthony Capobianco

On 2 May 2019 the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued "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 (SCP). In addition to the five key components, OFAC highlights "root causes" of sanctions violations in the framework. This is the first time OFAC has offered detailed insight into the agency's expectations with respect to an organization's SCP. To date, organizations have generally referred to the OFAC Risk Matrix in assessing the effectiveness of their compliance measures. See 31 Code of Federal Regulations Part 501, Appendix A. The framework is not meant to replace the matrix but instead weaves components of the OFAC Risk Matrix into the various elements of the framework.

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