On 6th May, Paul Hastings published a detailed analysis of the Framework for OFAC Compliance Commitments, published on 2nd May.  The Framework outlines what OFAC views as the essential components of a Sanctions Compliance Programs (SCP).  It says that, in order to comply effectively with economic sanctions restrictions and requirements, many companies choose to implement risk-based SCP.  The article says that this guidance marks the first time that OFAC has provided explicit guidance to companies on its views of what should be included in an effective SCP, and appears to signal the latest instalment in its subtle-but-steady push to communicate more with the economic sanctions-user community regarding its enforcement and compliance expectations.  It says that many of the concepts will be familiar to compliance professionals generally, but some suggested measures are tailored to specific risks that arise in the sanctions compliance context; and other measures one might expect to see addressed are not included.


Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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