OFAC Compliance Program

General

Five Common Weaknesses in OFAC Sanctions Compliance Programs

As companies elevate their “game” in sanctions compliance, it is important that compliance officers critically examine the strengths and weaknesses of their compliance programs. Many companies already have a screening technology but little else beyond a basic screening process. From my vantage point, I have observed some common weaknesses: Segregation

General

OFAC Sanctions Compliance Insights from Standard Chartered Bank Enforcement Action (Part III of III)

The Treasury Department’s Office of Foreign Asset Control (OFAC) has promised to issue guidance on effective sanctions compliance programs. This is a long-anticipated update to prior information OFAC has released on the same subject. OFAC has raised the stakes for sanctions enforcement, especially with respect to Iran and