May 2, 2019: OFAC issues “A Framework for OFAC Compliance Commitments”

From Treasury:

OFAC Issues a Framework for Compliance Commitments

Washington – Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) is publishing A Framework for OFAC Compliance Commitments in order to provide organizations subject to U.S. jurisdiction, as well as foreign entities that conduct business in or with the United States or U.S. persons, or that use U.S.-origin goods or services, with OFAC’s perspective on the essential components of a sanctions compliance program. 

“As the United States continues to enhance our sanctions programs, ensuring that the private sector implements strong and effective compliance programs that protect the U.S. financial system from abuse is a key part of our strategy,” said Sigal P. Mandelker, Under Secretary for Terrorism and Financial Intelligence.

“OFAC developed this framework in our continuing effort to strengthen sanctions compliance practices across the board,” said Andrea M. Gacki, Director of the Office of Foreign Assets Control.  “This underlines our commitment to engage with the private sector to further promote understanding of, and compliance with, sanctions requirements.”

The document also outlines how OFAC may incorporate these components into its evaluation of apparent violations and resolution of investigations resulting in settlements.  Finally, the document includes an appendix that offers a brief analysis of some of the root causes of apparent violations of U.S. economic and trade sanctions programs OFAC has identified during its investigative process.

The first section of the document is broken down into 5 sections: Management Commitment, Risk Assessment, Internal Controls, Testing and Auditing, and Training. the second section discusses why programs are either inherently deficient or break down.

Mr. Watchlist will post each section of the document as separate blog posts over the next few days/weeks.

Link:

OFAC Notice

A Framework for OFAC Compliance Commitments

Treasury Press Release

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