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The Office of Foreign Assets Control (OFAC) administers and enforces U.S. economic sanctions programs in accordance with U.S. national security and foreign policy. OFAC had not previously published guidance addressing essential elements for an effective sanctions compliance program (SCP). It has now done so.

Specifically, on May 2, 2019, OFAC published guidance entitled “A Framework for OFAC Compliance Commitments.” OFAC’s Framework clearly establishes the agency’s expectations regarding an effective SCP. Given the importance OFAC places on an effective SCP in its enforcement decisions including the determination of the amount of any civil penalty, companies with international activities should consider whether to update their SCP to meet the agency’s standards.

In this update, we detail the OFAC Framework and outline several OFAC sanctions compliance breakdowns to avoid.