The Treasury Department’s Office of Foreign Asset Control is an enforcement agency – it is not a regulatory agency. That sounds like a lot of bureaucratic speak but it does have some real significance. OFAC staff view themselves and act like an enforcement agency. Yes, they regulate in the sense that they authorize general and specific licenses and provide guidance. OFAC guidance is sometimes provided...
If you follow my blog, you know I am not one to embrace hyperbole. So, forgive me for stretching a little here, but the OFAC Framework for Sanctions Compliance Programs is a game changer. Let me explain why I am saying that. When it comes to sanctions compliance programs, most companies are well behind the curve; I am not saying they do nothing, but most...
Webinar: OFAC Issues New Framework for Sanctions Compliance Programs Sign Up HERE May 22, 2019, 12 Noon EST On May 2, 2019, the Treasury Department’s Office of Foreign Asset Control (“OFAC”) issued its promised guidance for sanctions compliance programs (“SCP”) (Here). OFAC “strongly encourage[d]” companies subject to OFAC jurisdiction to implement a “risk- based approach to sanctions compliance by developing, implementing and routinely updating a...
The Volkov Law Group has scheduled a free webinar to review OFAC’s new Framework for Sanctions Compliance Programs for May 22, 2019, at 12 Noon EST. Sign Up Here. OFAC’s new Framework for Sanctions Compliance Programs incorporates a number of important principles from Justice Department and US Sentencing Guideline requirements for effective compliance programs. Today, I am going to review the requirements relating to Testing...
The Volkov Law Group has scheduled a free webinar to review OFAC’s new Framework for Sanctions Compliance Programs for May 22, 2019, at 12 Noon EST. Sign Up Here. OFAC’s Framework for Sanctions Controls Program is a heightening of the importance of ethics and compliance program and reflects significant expectations for implementing effective compliance strategies. Risk Assessment In Risk Assessment, OFAC recommends that organizations conduct...
The Volkov Law Group has scheduled a free webinar to review OFAC’s new Framework for Sanctions Compliance Programs for May 22, 2019, at 12 Noon EST. Sign Up Here. 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”) (Here). ...
