The New “Framework for OFAC Compliance Commitments”: What You Need to Know

On May 2, 2019, the United States Treasury’s Office of Foreign Assets Control (OFAC) issued a Framework for OFAC Compliance Commitments.  The Framework was expressly designed to provide “OFAC’s perspective on the essential components of a sanctions compliance program.”  The document also outlines how these elements will be considered in the event of an enforcement action, and analyzes the root causes of economic sanctions violations that OFAC has identified in its investigative process.  The document is essential reading for all compliance professionals, and its lessons must be incorporated into any effective compliance program.  This webinar will cover the Framework itself and the lessons it provides for adapting U.S. sanctions compliance policies and procedures.  The webinar will also cover how the Framework should affect U.S. sanctions investigations and interactions with OFAC officials as part of the enforcement process.