On May 2, 2019, the US Treasury Department publicly released additional guidance on its expectations regarding corporate sanctions programs, A Framework for OFAC Compliance Commitments. The guidance comes on the heels of over $1.2 billion in Office of Foreign Assets Control (OFAC)–related settlements and penalties levied in 2019 to date (versus $71 million in 2018). It also follows guidance issued by the US Department of Justice in late April 2019 regarding Evaluation of Corporate Compliance Programs. Together, the releases seem to signal a cross-departmental desire to provide entities subject to OFAC regulation with a clearer roadmap of how to tackle the challenges of corporate integrity proactively, and in so doing help mitigate penalties when facing potential violations.

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