Guidance on the United States Sanctions Compliance Programmes Published by the Office of Foreign Assets Control (5.573)

This circular explains the guidance published by the United States Office of Foreign Assets Control on the key elements of an effective sanctions compliance programme.

London P&I highlights OFAC’s expectations for management commitment, risk assessment, internal controls, testing and auditing, and training, and notes the importance of reviewing and updating compliance arrangements in line with applicable sanctions regimes.