New Guidance on OFAC Sanctions Compliance Programs

On May 2, 2019, the Office of Foreign Assets Control (“OFAC”) issued its “Framework for OFAC Compliance Commitments” presenting a number of recommendations for the design, implementation and periodic update of Sanctions Compliance Programs (“SCPs”) by “organizations subject to U.S. jurisdiction and foreign entities that conduct business in or with the United States, U.S. persons, or using U.S.-origin goods or services.”