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On 2 May 2019, the US Office of Foreign Assets Control (OFAC) published A Framework for OFAC Compliance Commitments (Framework). This long-awaited document sets out OFAC’s expectations for effective sanctions compliance programs (SCPs). While the broad elements of the Framework should be familiar to seasoned compliance practitioners, the details highlight…

On April 30, 2019, the Assistant Attorney General for the Department of Justice’s Criminal Division, Brian Benczkowski, announced the publication of an updated version of the Department’s Guidance Document on Evaluation of Corporate Compliance Programs (the “Revised Evaluation Guidance”). This is an update to the original version of the Department’s…