Geoff Martin


On May 2, 2019, the US Office of Foreign Assets Control (“OFAC”) published A Framework for OFAC Compliance Commitments (the “Framework”).  This long-awaited document sets out OFAC’s expectations for effective sanctions compliance programs (“SCPs”).  While the broad elements of the Framework should be familiar to seasoned compliance practitioners, the details highlight the specific significance that OFAC attaches to SCPs in resolving enforcement actions.  Indeed, we are already seeing OFAC settlements conditioned on compliance enhancements reflected in the Framework.