“People have originally long thought of OFAC as a banking enforcement agency,” Mr. Smith said. “But we’re seeing a lot of aggressiveness on the non-bank side and that’s a big change.”

It's been a busy year for OFAC, updating rules for rejecting transactions, pursing individual liability for compliance, and updating its framework for sanctions compliance. The key concepts for all companies in avoiding sanctions pain include:

  • Reviewing and approving the organization’s sanctions compliance program
  • Delegating sufficient authority and autonomy to sanctions compliance teams
  • Ensuring that the organization’s compliance unit(s) receive adequate resources
  • Promoting a culture of compliance
  • Recognition of shortfalls in sanctions controls

Our approach includes assisting organization with the following compliance components with efficient, defensible program improvements:

  • Management Oversight
  • Risk Assessment
  • Internal Controls
  • Testing & Validation
  • Training
  • Investigations