Insight
OFAC's new framework provides further insight into leading practices to mitigate the risk of sanctions penalties.
OFAC notes that it has identified deficiencies or weaknesses that are common among companies subject to enforcement actions.
A framework for OFAC compliance commitments: an overview
On May 2, 2019, the Office of Foreign Assets Control (OFAC) released "A Framework for OFAC Compliance Commitments" (the Framework), which details the agency's views on the most important elements of a sanctions compliance program (SCP).