Whatever happened to “strict liability,” OFAC?

From the “Risk Assessment” section of OFAC’s “A Framework for OFAC Compliance Commitments”:

OFAC recommends that organizations take a risk-based approach when designing of updating an SCP.

That flies in the face of everything OFAC has said over the years about sanctions being a strict liability regime. So, now imagine… if you have some level of risk-based flexibility, how might you run your sanctions compliance program differently?

Just sayin’…

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