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…

Plain-language summary

What it actually means.

to be determined

Plain-language summary forthcoming. Source text below.

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.

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
May 26, 2026 (29m ago)
Source
Framework for OFAC Compliance Commitments