OFAC outlines baseline considerations for evaluating a risk-based sanctions compliance program.

On May 2, 2019, the US Treasury Department’s Office of Foreign Assets Control (OFAC) published A Framework for OFAC Compliance Commitments (the Compliance Framework), which identifies five essential components of an effective Sanctions Compliance Program (SCP). While companies are not legally required to implement an SCP, a failure to adhere to these principles increases the risks of sanctions violations and more aggressive enforcement by OFAC when violations do occur.