OFAC Publishes Sanctions Compliance Guidance and Identifies Root Causes of Violations

Last week, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published “A Framework for OFAC Compliance Commitments” setting out not only the five essential components of an effective U.S. sanctions compliance program, but also identifying the most prominent “root causes” of recent sanctions violations. The root cause discussion is particularly noteworthy as it highlights potential landmines for both U.S. and non-U.S. companies to avoid as they seek to navigate the complexities of U.S. sanctions compliance. 

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