Tagged: OFAC sanctions compliance program

OFAC Sanctions Compliance: 2019 a Game-Changing Year (Part II of II)

I usually ignore hyperbole.  I cringe when I hear, “[Title] was the greatest movie of all time,” or “[Title] was the greatest book of all time” (true confession — except if someone fills in the blank with The Brothers Karamazov by Fyodor Dostoevsky). Moving on, 2019 was a big year in OFAC compliance.  The Sanctions Compliance Guidance (here) was a major change in sanctions compliance. ...

Episode 92 — How to Implement a Sanctions Compliance Program

OFAC’s new  Framework for Sanctions Compliance Programs is a game changer.   When it comes to sanctions compliance programs, most companies are well behind the curve.  OFAC’s new framework raises the bar by creating a well-crafted framework for companies to assess their current program and then re-design important elements to meet OFAC’s standards.    To the extent that a company’s sanctions compliance program operates as part of an overall...