TRACE_Logo_Tagline_SMALL PNG

Does Your Sanctions Compliance Program Align with OFAC’s 2019 Compliance Framework?

A TRACE WHITE PAPER

TRACE WHITE PAPER

 

Screen Shot 2020-06-10 at 2.56.01 PM

 

In May 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the agency responsible for administering and enforcing economic sanctions, released “A Framework for OFAC Compliance Commitments," which outlines what OFAC views as the essential components of a sanctions compliance program. In this white paper, Paul Hastings LLP breaks down the elements of the Framework and provides practical guidance for ensuring that a compliance program aligns with OFAC's expectations, including:

  • the seven internal controls that should be included in a sanctions compliance program;
  • three key areas of focus for risk assessments;
  • new guidance around testing and auditing; and
  • the ten root causes of sanctions violations.

DOWNLOAD YOUR COPY