The Department of the Treasury’s Office of Foreign Assets Control (OFAC) published a framework for sanctions compliance yesterday which describes the sanctions compliance program standards for US legal and natural persons and for US-origin goods or services. The framework mirrors the requirements for a competence AML program and includes:
- commitment from the top down in writing.
- creation of sanctions committee of senior management to drive and support the sanctions compliance program and inculcate a culture of compliance.
- undertaking a risk assessment to identify risks of sanctions exposure.
- creation of internal controls, including policies and procedures after the risk assessment.
- testing and auditing of the program to ensure that it is effective, responds to the risk assessment and can identify weaknesses and gaps for remediation.
- training on an on-going basis of personnel across the organization.
The framework also describes the most common ways in which sanctions are violated, inadvertently or otherwise and those include lack of a program, lack of legal advice in respect of the law of sanctions or a misinterpretation of sanctions law, facilitating sanctions using foreign subsidiaries or affiliates.
Meanwhile, in Iran, people were posting the opening of crypto mining operations for international transfers.
Bitcoin mining in Iran published on Twitter.
