On May 2, 2019, the US Department of the Treasury, Office of Foreign Assets Control (OFAC) published “A Framework for OFAC Compliance Commitments”. This document addresses the requirements of an effective risk-based and on-going sanctions compliance programs (SCPs). In addition, the Framework outlines the five (5) essential components of a risk-based SCP: management commitment; risk assessment; internal controls; testing and auditing and training. To Access full article: Click here