It’s the most detailed statement to-date of OFAC’s views on the best practices that companies should follow to ensure compliance with U.S. sanctions laws and regulations, and some would call it a total “game changer.”
It’s meant to be a roadmap for ABAC compliance practitioners working to prevent sanctions violations from occurring in the first place and, when violations do occur, to provide greater transparency with respect to how OFAC will assess the adequacy of a company’s existing compliance program in determining what penalty to impose.
OFAC itself said the Framework “strongly encourages” companies subject to its jurisdiction to take a “risk-based approach to sanctions compliance by developing, implementing and routinely updating a sanctions compliance program.” OFAC recognizes that all businesses are different in “size and sophistication, products and services, customers and counterparties and geographic locations.” To this end, each compliance program should not be a cookie-cutter, off-the-shelf solution.
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