What Happened: On May 2, 2019 US Department of
Treasury's Office of Foreign Assets Control (OFAC) published
"A Framework for OFAC Compliance Commitments" (the
Framework), which provides a specific outline of what OFAC
considers to be essential elements of an effective sanctions
compliance program (SCP). OFAC also released a settlement with
MID-SHIP Group LLC (MID-SHIP), a US-based shipping and logistics
company, that demonstrates the benefits of a company's efforts
to achieve such "Compliance Commitments" included in the
Framework (and the consequences of non-compliance).
The Bottom Line: OFAC is using its most
forceful language to date on the need for an effective sanctions
compliance program and "strongly encouraging" companies
to identify and quantify their OFAC risks and to design and
implement OFAC compliance programs similar to those imposed on
financial institutions in respect of Anti-Money Laundering
compliance. Companies subject to US jurisdiction, as well
