Five months after Sigal Mandelker, Under Secretary of the US Treasury for Terrorism and Financial Intelligence, presented five of the hallmarks of an effective sanctions compliance program, the Office of Foreign Assets Control (OFAC) has finally published long-awaited guidance for national and international organizations subject to its regulation (the Framework). The inaugural “Framework for OFAC Compliance Commitments” is the most detailed statement to date of OFAC’s views on sanctions compliance best practices and will likely be incorporated into compliance programs for entities worldwide.
We provide a summary and analysis of OFAC’s Framework, focusing on tangible next steps a company can take away from the guidance about the essential elements of an effective sanctions compliance program.
