Companies have to implement a sanctions compliance program (SCP). The Treasury Department Office of Foreign Asset Control’s sanctions guidance issued in May 2019 is an extraordinary document and includes numerous prescriptive requirements.  Companies ignore the SCP Guidance at their peril.

The Treasury Department’s Office of Foreign Asset Control (OFAC) has a robust and mature enforcement program.  Over the last few years, OFAC has successfully expanded its enforcement focus beyond the financial industry and now targets manufacturing, service and other industries. The Justice Department expects companies to voluntarily disclose potential sanctions violation where there is evidence that the violation may be willful.

In this Episode, Michael Volkov reviews five basic steps companies should take to implement a sanctions compliance program.