![]() ![]() ![]() jurisdiction review the settlements published by OFAC to reassess and enhance their respective, when and as appropriate.” As the Framework notes, “OFAC recommends all organizations subject to U.S. Instead of merely summarizing these compliance commitments, the MoFo national security team has linked each commitment to the lessons of enforcement cases of the past year. Although OFAC reiterated that every company’s risk-based sanctions compliance program will vary based on its own individual risk factors – including the company’s size and sophistication, products and services, customers and counterparties, and geographic locations – OFAC characterized the five “essential components” of compliance as requiring: (1) management commitment (2) risk assessment (3) internal controls (4) testing and auditing and (5) training. As we indicated in our recent client alert outlining the top 20 compliance lessons to learn from the past year’s OFAC enforcement cases, OFAC has hinted at this Framework since last fall when it began publishing settlement agreements with compliance commitments included. Treasury Department’s Office of Foreign Assets Control (OFAC) published its first-ever Framework for OFAC Compliance Commitments (“Framework”), detailing the essential components of a sanctions compliance program, and the contents were hardly a surprise.
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