Further emphasizing its expectation that all companies whose business touches on the United States should maintain a robust, risk-based US economic sanctions compliance program (“SCP”), the US Treasury’s Office of Foreign Assets Control (“OFAC”) has published a detailed “Framework for OFAC Compliance Commitments” (the “Framework”) setting forth the key components of an adequate SCP. OFAC’s […]

If any business thinks getting caught evading a sanctions program of the US Office of Foreign Assets Control (OFAC) is inconsequential in money and reputation, they should look closely at the settlement agreements OFAC signs with each penalized business. Like clockwork, at a rate of 5.9 cases per month from April 4, 2003 to February […]