OFAC’s New Framework for an Effective Sanctions Compliance Program Provides Important Risk Mitigation Advice

• 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.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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