What Is an OFAC Compliance Program?
The five-pillar OFAC compliance program, explained.
Overview
OFAC's Framework for Compliance Commitments describes five pillars. A compliance program is the documented implementation of all five - for agents, each pillar has a technical shape.
The pillars
- Management commitment - a designated compliance owner
- Risk assessment - where the risk lives, scored
- Internal controls - screening, fail-closed, no override
- Testing - verify controls with known sanctioned parties
- Training - the people around the program
Why it matters
OFAC treats a documented program as a mitigating factor - and it is the answer an inquiry demands. The framework post details each pillar.
The starting point
Screen before sign + log everything + document the program. The policy template is the document skeleton.