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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.

 

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Photo of Richard Oehler Richard Oehler

Highly experienced in counselling and representing companies on U.S. regulatory matters, Richard Oehler concentrates his counsel in the areas of economic sanctions, national security and Committee on Foreign Investment in the United States (CFIUS), federal procurement, export controls and Foreign Corrupt Practices Act…

Highly experienced in counselling and representing companies on U.S. regulatory matters, Richard Oehler concentrates his counsel in the areas of economic sanctions, national security and Committee on Foreign Investment in the United States (CFIUS), federal procurement, export controls and Foreign Corrupt Practices Act (FCPA) issues.

Photo of Ann M. Nagele Ann M. Nagele

Ann Nagele is a partner in the firm’s Corporate practice and is based in the Seattle office. She focuses her practice on international trade matters and she also has experience with a wide variety of licensing and technology transactions.