October 28, 2026, 12 Noon EDT

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OFAC’s 2019 Framework for Compliance Commitments is still the foundational document every sanctions compliance program should be built on, but if your program hasn’t been updated since then, it no longer reflects how sanctions enforcement actually works today. Since 2023, the Department of Justice, the Department of Commerce’s Bureau of Industry and Security, and OFAC have been issuing joint “Tri-Seal” compliance notes that layer substantial new expectations on top of the original framework, reflecting a genuinely coordinated, multi-agency approach to sanctions and export control enforcement. This isn’t a minor technical update. It touches how far U.S. jurisdiction reaches into foreign subsidiaries, how voluntary self-disclosure decisions get evaluated, how deeply supply chains need to be screened for evasion tactics, and how long your organization needs to retain records before a past transaction is truly in the clear.

Join Michael Volkov for a practical session on what’s actually changed and what it means for your compliance program. We’ll walk through the five pillars of the 2019 Framework and why they remain your essential foundation, then dig into the four multi-agency priorities reshaping enforcement: the expanding reach of “U.S. nexus” jurisdiction and foreign subsidiary liability, harmonized voluntary self-disclosure expectations where staying silent is now treated as an aggravating factor, granular supply chain and “know-your-cargo” evasion detection requirements, and OFAC’s extension of its enforcement statute of limitations from five years to ten. You’ll leave with a concrete roadmap for mapping these priorities onto your existing program, whether that means expanding your risk assessment, upgrading your screening beyond simple name-matching, or rebuilding your recordkeeping around the new ten-year lookback window.