Much already has been written by my colleagues about the Office of Foreign Assets Control (“OFAC”) Framework for Compliance Commitments, which was published on May 2, 2019.  Very briefly, the Framework provides OFAC’s expectations that sanctions compliance programs (SCP), should include at least five essential components of compliance: (1) management commitment; (2) risk assessment; (3) internal controls; (4) testing and auditing; and (5) training I think it was an excellent development that OFAC, which generally is not known for being … Read More