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U.S. framework for complying with sanctions programs (OFAC)

U.S. framework for complying with sanctions programs

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) today released a guidance document that is intended to be used by entities that are subject to the U.S. jurisdiction—and by foreign entities that conduct business in or with the United States or U.S. persons, as well as foreign entities that use U.S.-origin goods or services—to comply with OFAC’s standards with regard to the components of a U.S. sanctions compliance program.

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The document—A Framework for OFAC Compliance Commitments [PDF 138 KB]—outlines how OFAC may incorporate these components into its evaluation of apparent sanction violations and in resolution of investigations resulting in settlements. 

In general, the OFAC framework notes that each risk-based sanctions compliance program varies depending on a variety of factors—including the company’s size and sophistication, products and services, customers and counterparties, and geographic locations—each program is predicated on and incorporates at least five essential components of compliance: (1) management commitment; (2) risk assessment; (3) internal controls; (4) testing and auditing; and (5) training.

The OFAC document includes an appendix that offers a brief analysis of some of the root causes of apparent violations of U.S. economic and trade sanctions programs that OFAC has identified during its investigative process.​

 

For more information on this topic or to learn more about KPMG’s Trade & Customs Services, contact:

Doug Zuvich
Partner and Global Practice Leader
T: 312-665-1022
E: dzuvich@kpmg.com

John L. McLoughlin
Principal and East Coast Leader
T: 267-256-2614
E: jlmcloughlin@kpmg.com

Andy Siciliano
Partner and National Practice Leader
T: 631-425-6057
E: asiciliano@kpmg.com

Luis (Lou) Abad
Principal, Washington National Tax
T: 212-954-3094
E: labad@kpmg.com

Irina Vaysfeld
Principal
T: 212-872-2973
E: ivaysfeld@kpmg.com

Amie Ahanchian
Managing Director
T: 202-533-3247
E: aahanchian@kpmg.com

Robert Waldrop
Principal
T: 212-954-8117
E: rwaldrop@kpmg.com

Gisele Belotto
Managing Director
T: 305-913-2779
E: gbelotto@kpmg.com

Christopher Young
Principal
T: 312-665-3229
E: christopheryoung@kpmg.com

Andy Doornaert
Managing Director
T: 313-230-3080
E: adoornaert@kpmg.com

George Zaharatos
Principal
T: 404-222-3292
E: gzaharatos@kpmg.com

Jessica Libby
Managing Director
T: 612-305-5533
E: jlibby@kpmg.com

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