Compliance Lessons in Recent Office of Foreign Assets Control Enforcement

In May 2019, the US Department of the Treasury's Office of Foreign Assets Control (OFAC), which administers US sanctions laws, issued a broad framework identifying what OFAC views as the essential elements of risk-based sanctions compliance. At the same time, OFAC announced that it would consider how well these elements have been incorporated when considering its enforcement response to sanctions violations.

While providing general guidance, the framework provides little in the way of practical detail to assist financial institutions with incorporating the framework into their organizations. Perhaps in recognition, OFAC recommended that all organizations review enforcement actions published by OFAC for purposes of reassessing and enhancing sanctions compliance. This paper is intended to help financial institutions comply with OFAC's recommendation by identifying critical guidance and common pitfalls in a survey of post-framework enforcement actions.

Originally published in the Journal of Financial Compliance; reprinted with permission.