In May 2019, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published the Framework for OFAC Compliance Commitments (“Framework”), which is intended to help organizations subject to U.S. jurisdiction, as well as foreign entities doing business in or with the United States, U.S. persons, or using U.S.-origin goods or services, to develop and implement an export control and economic sanctions compliance program (SCP). While acknowledging that each company’s SCP will vary depending upon a variety of company-specific and risk‑based factors, OFAC has indicated that any program should include, at a minimum, the following compliance components: (1) management commitment; (2) risk assessment; (3) internal controls; (4) testing and auditing; and (5) training.

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