Anti-Corruption and Anti-Bribery

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Corporate Compliance in a Geopolitical World: OFAC’s Framework for Compliance Commitments

As the world continues to shrink and geopolitical risks continue to grow, incorporating a robust sanctions compliance program (SCP) into a company’s broader compliance and ethics program is a must.

To support companies in the implementation of an effective SCP, on May 2, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published A Framework for OFAC Compliance Commitments[2] “in order to provide organizations subject to U.S. jurisdiction, as well as foreign entities that conduct business in or with the United States or U.S. persons, or that use U.S.-origin goods or services, with OFAC’s perspective on the essential components of a sanctions compliance program.”[3] In addition to providing guidance on the implementation of an effective SCP, the framework “outlines how OFAC may incorporate these components into its evaluation of apparent violations and resolution of investigations resulting in settlements” and “offers a brief analysis of some of the root causes of apparent violations of U.S. economic and trade sanctions programs OFAC has identified during its investigative process.”

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