On May 2, 2019, the United States Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued its “Framework for OFAC Compliance Commitments” presenting OFAC’s new recommendations for the design, implementation and 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.” (“OFAC’s Guidelines”).
