OFAC’s new  Framework for Sanctions Compliance Programs is a game changer.   When it comes to sanctions compliance programs, most companies are well behind the curve.  OFAC’s new framework raises the bar by creating a well-crafted framework for companies to assess their current program and then re-design important elements to meet OFAC’s standards.   

To the extent that a company’s sanctions compliance program operates as part of an overall ethics and compliance program (which it should), a company should already be well positioned in a number of areas that are generally applicable to all ethics and compliance programs.  When it comes to some of the more specific sanctions risks, the definition of these sanctions’ risks, and the prescriptive elements of OFAC’s framework, that is where companies need to get to work and implement improvements. 

In this Episode, Michael Volkov discusses important elements for organization’s to assess and craft program improvements.