Officials from the US Office of Foreign Assets Control (OFAC) have been teasing for months that they would issue guidelines to help companies comply with US sanctions regulations. On 2 May 2019, OFAC made good and published the much-anticipated "A Framework for OFAC Compliance Commitments" (the Framework) outlining the five essential components of an effective sanctions compliance program.
The Framework comes at a time when OFAC is more focused than ever on bringing enforcement actions against companies in Asia, as illustrated by the cases we discuss below. The Framework puts companies on notice that OFAC expects non-US companies, especially those in higher risk industries, to adopt risk-based compliance programs to minimize the possibility of violations. For companies with nonexistent or weak sanctions compliance programs, it's never too late to start building one, using the Framework as a handy blueprint.