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 mining operations for international transfers.