OFAC Sanctions Compliance Policy

Summary

This Office of Foreign Assets Control (OFAC) Sanctions Compliance Policy template can be used by a company in order to inform personnel of the company's expectations for ensuring OFAC compliance. This template includes practical guidance and drafting notes. OFAC, which is part of the U.S. Treasury Department, promulgates and implements regulations to administer and enforce U.S. economic sanctions. It is important that any party engaged in or contemplating international business understand how to navigate the applicable statutes, regulations, lists, and agency directives and guidance so as to ensure compliance with its U.S. sanctions obligations. OFAC sanctions violations can result in severe civil and criminal penalties against offending companies and individuals, as well as potential imprisonment for willful violations. Accordingly, companies should develop and adopt, and ensure personnel are aware of, a clear OFAC sanctions policy. For a full listing of key content that can be used by in-house counsel to develop, revise, and implement a company's employee and third-party-related policies, see In-House Company Policies Resource Kit. For a full listing of key materials necessary to develop consumer-related bank policies and procedures central to regulated depository institution operations, see Developing Bank Policies and Procedures Resource Kit. For more information on OFAC, see OFAC Regulations Fundamentals. For more information regarding OFAC violations responses, see OFAC Violation Response Checklist and OFAC Violation Responses.