Episode 90 — OFAC Issues New Framework for Sanctions Compliance Program
On the heels of the Justice Department’s announcement of its new compliance guidance, on May 2, 2019, the Treasury Department’s Office of Foreign Asset Control (“OFAC”) issued its promised guidance for sanctions compliance programs (“SCP”).
Together with its aggressive enforcement of economic sanctions, OFAC has set a new standard for SCPs, and has “strongly encourage[d]” companies and individuals subject to OFAC jurisdiction to implement a “risk- based approach to sanctions compliance by developing, implementing and routinely updating a SCP.”
Michael Volkov discusses OFAC’s new guidance and the importance of sanctions compliance programs.
2 Responses
[…] Check out Mike Volkov’s 5-part blog post series on the new OFAC compliance program on his blog site, Corruption, Crime and Compliance. (Part 1, Part 2, Part 3, Part 4) For those who prefer the podcast format, you can list to his podcast on the topic here. […]
[…] Check out Mike Volkov’s 5-part blog post series on the new OFAC compliance program on his blog site, Corruption, Crime and Compliance. (Part 1, Part 2, Part 3, Part 4) For those who prefer the podcast format, you can list to his podcast on the topic here. […]