Publication of “A Framework for OFAC Compliance Commitments”

Yesterday, the U.S. Treasury’s Office of Foreign Asset Controls (OFAC) published A Framework for OFAC Compliance Commitments. The purpose of the framework is to provide organizations subject to U.S. jurisdiction, as well as foreign entities that conduct business in or with the United States or U.S. persons, or that use U.S.-origin goods or services, with guidelines on the essential components of a sanctions compliance program. The document also outlines how OFAC may incorporate these components into its evaluation of apparent violations and resolutions of investigations resulting in settlements.  Finally, the document includes an appendix that offers a brief analysis of some of the root causes of violations of U.S. economic and trade sanctions programs.