OFAC Compliance Program Template
The five-pillar OFAC compliance program template for payment and agent teams.
How to use
How to use: this template mirrors the five pillars OFAC expects in a compliance program. Fill in the bracketed fields.
The five pillars
- Management commitment: senior sign-off and resourcing for [Company] sanctions compliance, reviewed [quarterly].
- Risk assessment: product surface (wallets, names, jurisdictions), customer types, and agent autonomy reviewed [annually].
- Controls: pre-transaction screening (947 wallets, 19,218 names, 16 jurisdictions), fail-closed behavior, escalation to [Owner].
- Testing & audit: independent review of screen logs and controls [quarterly]; full audit [annually].
- Training: compliance and engineering teams trained on sanctions obligations [annually].
Why the template exists
OFAC's framework for evaluating compliance programs names exactly these five pillars. A documented program is the difference between a mitigating factor and a finding.