No. 8 2019/2020: Guidance on the U.S Sanctions Compliance Programmes by OFAC
The United States Treasury Department’s Office of Foreign Assets Control published a framework which sets out its views of the essential elements of an effective economic sanctions compliance programme.
The programme of activities that OFAC expect a company to follow includes a demonstrable U.S. sanctions compliance programme, sanctions risk assessment and risk audit procedures. Details are described in the OFAC Compliance Framework appended to this circular.
Members are advised to ensure that they adhere to all applicable sanctions regimes whether they originate from the Untied Nations, European Union or unilaterally by a Single state.
All International Group clubs have issued a similar circular.
Framework for OFAC Compliance Commitments PDF (138.3 KB)