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...