Sanctions Compliance Program Archives - Corruption, Crime & Compliance

22 May, 2023

Episode 275 — Five Steps to Enhance Your Sanctions Compliance Program

Even with the current focus on sanctions compliance, many companies have done little to assess and enhance their existing sanctions compliance program. Instead, companies have stitched together a basic sanctions compliance program that centers on a screening tool and little beyond that. Such a limited program provides just a false comfort of compliance. Many companies are not even conducting the mandated basic requirement of annual...

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12 Sep, 2021

Episode 206 — Update on Sanctions Compliance and Enforcement

The Department of Treasury’s Office of Foreign Asset Control (“OFAC”) continues to bring sanctions enforcement actions. At the same time, OFAC is reiterating the importance of sanctions compliance program. Building on its May 2019 Framework for Sanctions Compliance Program, OFAC is sticking to its word — setting forth sanctions compliance program requirements and holding companies accountable for sanctions program violations. In this Episode, Michael Volkov...

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18 Mar, 2020

Webinar: How to Implement an Effective OFAC Sanctions Compliance Program

Webinar: How to Implement an Effective OFAC Sanctions Compliance Program 12 Noon EST, March 31, 2020 Sign Up HERE In 2019, the Department of Treasury’s Office of Foreign Asset Control (OFAC) issued important guidance on sanctions compliance programs. OFAC’s guidance sets out new and prescriptive requirements for sanctions compliance programs. At the same time, OFAC has ramped up enforcement efforts. The Justice Department revised its...

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30 Jul, 2019

Five Common Weaknesses in OFAC Sanctions Compliance Programs

As companies elevate their “game” in sanctions compliance, it is important that compliance officers critically examine the strengths and weaknesses of their compliance programs. Many companies already have a screening technology but little else beyond a basic screening process. From my vantage point, I have observed some common weaknesses: Segregation of Duties and Control Process: Many companies maintain a screening program and assign the responsibility...

Episode 94 — How to Conduct a Risk Assessment for Sanctions Compliance

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16 Jun, 2019

Episode 94 — How to Conduct a Risk Assessment for Sanctions Compliance

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. The scope of a risk assessment has to mirror the breadth of enforcement risks and has to include review of: (i) customers, supply chain, intermediaries, and counter-parties; (ii) the products and services it offers, including how and where such items fit into...

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18 Apr, 2019

OFAC Sanctions Compliance Insights from Standard Chartered Bank Enforcement Action (Part III of III)

The Treasury Department’s Office of Foreign Asset Control (OFAC) has promised to issue guidance on effective sanctions compliance programs. This is a long-anticipated update to prior information OFAC has released on the same subject. OFAC has raised the stakes for sanctions enforcement, especially with respect to Iran and Venezuela sanctions programs. So far this year, OFAC has announced a number of significant enforcement actions and...