Episode 174: Five Basic Steps to Implement a Sanctions Compliance Program
Companies have to implement a sanctions compliance program (SCP). The Treasury Department Office of Foreign Asset Control’s sanctions guidance issued in May 2019 is an extraordinary document and includes numerous prescriptive requirements. Companies ignore the SCP Guidance at their peril. The Treasury Department’s Office of Foreign Asset Control (OFAC) has a robust and mature enforcement program. Over the last few years, OFAC has successfully expanded its enforcement...