OFAC’s Framework for Trade Compliance – Does It Apply to You?

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

Trade compliance issues keeping us up at night

As I embark on the exciting journey of running my own trade law practice, I am thinking about the issues that are most likely to be on top of mind for you – fellow legal and trade compliance professionals. This is why I decided to name this blog Thinking Trade. Here I plan to periodically highlight and analyze regulatory developments and trends that are (or should be) high on the minds of people charged with keeping their companies’ cross-border trade … Read More

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