In a May 2, 2019, press release, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) announced new guidance for companies and persons that conduct business activities in the United States or use U.S.-origin goods or services. “A Framework for OFAC Compliance Commitments” is intended for organizations under U.S. jurisdiction as well as foreign entities and foreign nationals engaged in business activities with U.S. persons in an effort to aid them in complying with U.S. sanctions.

The document examines a variety of topics with specific emphasis and discussion of the following:

• Management commitment;
• Risk assessment;
• Internal controls;
• Testing and auditing;
• Training; and
• Analysis of certain “root causes” of the OFAC sanctions compliance program breakdowns or deficiencies.

The publication also discusses how OFAC “may incorporate these components into its evaluation of apparent violations and resolution of investigations resulting in settlements.”

For More Information

If you would like further information about this Alert, please contact Brian S. Goldstein, any member of the International Practice Group or the attorney in the firm with whom you are regularly in contact.

Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.