Tagged: OFAC framework for sanctions compliance programs

Understanding the OFAC Sanctions Enforcement Guidelines (Part I of II)

Understanding the OFAC Sanctions Enforcement Guidelines (Part I of II)

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...

Webinar: OFAC Issues New Framework for Sanctions Compliance Programs

Webinar: OFAC Issues New Framework for Sanctions Compliance Programs

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...

OFAC Framework for Sanctions Compliance Programs – Testing and Auditing and Training (Part III of IV)

OFAC Framework for Sanctions Compliance Programs – Testing and Auditing and Training (Part III of IV)

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...

OFAC Framework for Sanctions Compliance Programs – Risk Assessment and Internal Controls (Part II of IV)

OFAC Framework for Sanctions Compliance Programs – Risk Assessment and Internal Controls (Part II of IV)

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...

OFAC Joins the Compliance Club – Issues Framework for Sanctions Compliance Programs (Part I of IV)

OFAC Joins the Compliance Club – Issues Framework for Sanctions Compliance Programs (Part I of IV)

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). ...