ST0666DOTOFAC

ST0666

While there is no “one-size-fits all” risk assessment, the exercise should generally consist of a holistic review of the organization from top-to-bottom and assess its touchpoints to the outside world. This process allows the organization to identify potential areas in which it may, directly or…

Source text

As written.

While there is no “one-size-fits all” risk assessment, the exercise should generally consist of a holistic review of the organization from top-to-bottom and assess its touchpoints to the outside world.  This process allows the organization to identify potential areas in which it may, directly or indirectly, engage with OFAC-prohibited persons, parties, countries, or regions. For example, an organization’s SCP may conduct an assessment of the following: (i) customers, supply chain, intermediaries, and counter-parties; (ii) the products and services it offers, including how and where such items fit into other financial or commercial products, services, networks, or systems; and (iii) the geographic locations of the organization, as well as its customers, supply chain, intermediaries, and counter-parties.  Risk assessments and sanctions-related due diligence is also important during mergers and acquisitions, particularly in scenarios involving non-U.S. companies or corporations.

Change history

When and why it changed.

Present in the original catalog

This standard has not changed since it was added.

Assessed by HEXDI

What HEXDI assesses.

  • M2

    1 — PROGRAM SETUP AND ADMINISTRATION

    Program is developed using a reasoned methodology that is based on a thorough analysis and identification of risks pertaining to company…

  • M2

    2 — PROGRAM SETUP AND ADMINISTRATION

    Methodology includes monitoring, collecting, and reporting of information on the number of exports/imports, nature and number of…

  • M2

    3 — PROGRAM SETUP AND ADMINISTRATION

    Senior Management, with the assistance of legal counsel and/or compliance personnel, takes responsibility for determining the significance…

  • M2

    4 — PROGRAM SETUP AND ADMINISTRATION

    Risk analysis and identification occurs at Senior Management meetings as part of short- and long-term forecasting and strategic planning.

  • M2

    5 — PROGRAM SETUP AND ADMINISTRATION

    Risk analysis and identification considers customer base, countries of exports/import activities, and product lines.

  • M2

    6 — PROGRAM SETUP AND ADMINISTRATION

    Risk analysis and identification considers risks posed by interactions with third parties, to include suppliers, brokers, contractors,…

Source & revisions

First mapped
Jun 8, 2022
Last updated
Oct 28, 2026 (6d ago)
Source
Framework for OFAC Compliance Commitments