Compliance Communication (OFAC)

OFAC’s compliance guidance is set principally by A Framework for OFAC Compliance Commitments (2 May 2019), which lists five components OFAC weighs when evaluating a sanctions compliance program and assessing penalties: management commitment, risk assessment, internal controls, testing and auditing, and training. It is not a regulation but signals enforcement expectations. For shipping it underpins the due-diligence measures later detailed in OFAC’s 14 May 2020 maritime advisory, including AIS monitoring and contractual sanctions clauses.