OFAC said violations can be minimized if compliance programs include management commitment, risk assessment, internal controls, testing and auditing, and training.
The Treasury Department’s Office of Foreign Assets Control (OFAC), which administers and enforces U.S. economic and trade sanctions programs against targeted foreign governments, individuals, groups and entities for national security and foreign policy purposes, outlined five key elements that make up a successful corporate-level sanctions compliance program.
They include management commitment, risk assessment, internal controls, testing and auditing, and training, the agency said in a 12-page notice published Thursday.
“OFAC strongly encourages organizations subject to U.S. jurisdiction, as well as foreign entities that conduct business in or with the United States, U.S. persons or using U.S.-origin goods or services, to employ a risk-based approach to sanctions compliance by developing, implementing and routinely updating a sanctions compliance program (SCP),” the agency said.
Corporate commitment to these five elements of a U.S. sanctions compliance program often determines whether penalty amounts will be mitigated by the agency during investigations of alleged wrongdoing.