OFAC Releases Framework for Compliance
On May 2, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued “A Framework for OFAC Compliance Commitments”. The 12 page document sets forth 5 essential components for an OFAC compliance program:
(1) management commitment;
(2) risk assessment;
(3) internal controls;
(4) testing and auditing; and
(5) training.
OFAC emphasizes that a compliance program should be risk-based. Appendix A to 31 C.F.R. Part 501, OFAC’s Economic Sanctions Enforcement Guidelines, provides an OFAC risk matrix that can be utilized to develop a financial institution’s risk assessment.
CLA’s financial institution regulatory compliance team assists banks and credit unions nationwide in establishing regulatory compliance programs, conducting compliance testing, and training staff on regulations. Justin Robinson is a member of CLA’s regulatory compliance team and can be reached at justin.robinson@CLAconnect.com.
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