Not all sanctions violations are willful.

Some companies just don’t know any better.

An effective trade compliance program needs three critical elements.

First, in addition to the two we spoke about in the last episode, organizations and companies have to monitor transactions, shipping documents, vessels, payment flows, and escalation of red flags.

Employee training is critical.

OFAC’s compliance framework specifically identifies training as a core compliance expectation.

And finally, organizations need to monitor, audit, and test whether their controls are actually working.

A compliance program that is never tested is simply operating on assumptions.

The best trade compliance programs don’t just detect violations, they prevent them.

The Ethics and Compliance Q and A show is produced by One Stone Creative.