Tagged: OFAC Compliance Internal Controls

Making Sure Your Internal Controls Address Sanctions Risks (Part III of IV)

Making Sure Your Internal Controls Address Sanctions Risks (Part III of IV)

The term “internal controls” is a loaded one – it morphs in various ways depending on the context.  Sometimes it is a shorthand for financial accounting controls; other times it encompasses a company’s compliance controls (i.e. policies and procedures). OFAC embraced the term to equate with a company’s policies and procedures for sanctions compliance.  OFAC recognized that OFAC compliance functions have to begin with the...