On May 2, 2019, the United States Treasury’s Office of Foreign Assets Control (OFAC) issued a Framework for OFAC Compliance Commitments. The Framework was expressly designed to provide “OFAC’s perspective on the essential components of a sanctions compliance program.” The document also outlines how these elements will be considered in the event of an enforcement action, and analyzes the root causes of economic sanction...

US sanctions policy developments continue front and center in 2019... Over the past few years, sanctions regulations have continued to change at a rapid pace and in important ways. The Departments of Commerce and Treasury have introduced many significant changes to controls on countries and regions including Cuba, India, Iran, North Korea, Russia, Sudan, and Venezuela. In many of these cases these actions prohibit activities and impose new lic...