Key Takeaways From OFAC's Compliance Program Guidance

By Ama Adams, Brendan Hanifin and Emerson Siegle (May 28, 2019, 1:50 PM EDT) -- On May 2, the U.S. Department of the Treasury's Office of Foreign Assets Control published "A Framework for OFAC Compliance Commitments," setting out new sanctions compliance program guidance. The document represents OFAC's most complete articulation to date of the elements of an effective sanctions compliance program. This guidance appears to establish baseline expectations for assessing the sufficiency of companies' compliance programs in connection with future enforcement actions....

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