HEXDI Integrates Framework for OFAC Compliance Commitments

On May 2, 2019, the Department of Treasury Office of Financial Assets Control (“OFAC”) issued a Framework for OFAC Compliance Commitments. [F/N 1] The OFAC Framework strongly encourages organizations subject to U.S. jurisdiction to employ a risk-based approach to sanctions compliance by developing, implementing, and routinely updating a compliance program with at least five essential components of compliance:

1. management commitment;
2. risk assessment;
3. internal controls;
4. testing and auditing; and
5. training.

HEXDI has integrated 42 additional government standards reflected in the OFAC Framework, which are now included in HEXDI modules 1 through 12. 

[F/N 1] See Office of Foreign Assets Control, Framework for OFAC Compliance Commitments (May 2019), available at www.treasury.gov/resource-center/sanctions/Documents/framework_ofac_cc.pdf

The above is not intended as an exhaustive list of restrictions that may apply to a particular transaction nor advice for a specific transaction because the specifics of an individual case may implicate application of other U.S. laws as well as foreign laws that carry added or different requirements. In addition, U.S. export control and sanctions laws are frequently subject to change. Such changes can affect the continued validity of the information above.