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Key Takeaways From OFAC’s Compliance Program Guidance

Law360 (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.

Compliance Program Guidance Overview

The guidance states that “each [sanctions compliance] program should be predicated on and incorporate at least five essential components of compliance: (1) management commitment; (2) risk assessment; (3) internal controls;...

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