

OFAC Sanctions Compliance Programs
United States
2021
AML/CFT
Tax & Reporting
Overview
Key Obligations
- Conduct sanctions risk assessments to identify exposure based on products, services, geography, and counterparties
- Implement internal controls such as policies, procedures, and screening tools to detect prohibited transactions
- Carry out regular testing and auditing of sanctions compliance measures
- Ensure management commitment and allocation of sufficient resources to compliance functions
- Provide ongoing training for employees on sanctions obligations and red-flag scenarios
- Maintain records of transactions, counterparties, and screening results for regulatory review
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Related Regulations
FAQ
Who must comply with OFAC sanctions?
All U.S. persons and companies, including citizens, residents, U.S.-incorporated entities, and foreign branches.
Do non-U.S. companies need to comply?
Yes, if they conduct transactions involving U.S. persons, the U.S. financial system, or goods of U.S. origin.
What happens if a company violates sanctions?
OFAC may impose civil monetary penalties, enforcement actions, license restrictions, and reputational consequences.
Is a compliance program mandatory?
While not explicitly required by statute, OFAC strongly expects companies to have one. A robust program can be a mitigating factor in enforcement decisions.