Conducting a Sanctions Risk Assessment: A New Era for Analyzing Your Risks (Part II of IV)
OFAC’s new framework guidance for sanctions compliance programs stretched into new territory with its risk assessment requirement. This new approach reflects OFAC’s recent aggressive enforcement programs. In recognition of the importance of various economic sanctions programs, particularly Iran, North Korea and Venezuela, OFAC has laid out some important markers. These enforcement actions, e.g. the Epsilon case (here), and the elf Cosmetics case (here), and the...