Tagged: Framework for Sanctions Compliance Programs

The Elevation of Sanctions Compliance

This has been  an interesting enforcement year.  The Biden Administration promised a renewal of aggressive enforcement. The difficult transition from the last administration and political resistance to confirmation of political appointees has delayed the transition process.  Consequently, enforcement has gotten off to a slow start.  But companies would make a big mistake in embracing complacency or just waiting for enforcement to pick up before elevating...

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...