• The U.S. Department of the Treasury's Office of Foreign Assets Controls (OFAC) recently published guidance that describes the framework for an effective Sanctions Compliance Program (SCP). In its guidance, OFAC makes clear that an effective SCP can, in situations where OFAC determines a civil penalty will be assessed, mitigate the penalty assessed.

• OFAC's compliance framework, as set forth in its recent guidance, distills five "essential components of compliance" that should form the basis of all SCPs.

• Does your OFAC SCP measure up? We encourage you to try our two-minute selfassessment tool to find out.

The U.S. Department of the Treasury’s Office of Foreign Assets Controls (OFAC) recently published guidance that describes the framework for an effective Sanctions Compliance Program (SCP). In its guidance, OFAC makes clear that an effective SCP can, in situations where OFAC determines a civil penalty will be assessed, mitigate the penalty assessed.