Investigations / Compliance Consulting

Global Sanctions Compliance

J.S. Held’s Inaugural Global Risk Report Examines Potential Business Risks & Opportunities in 2024

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We address the full range of global sanctions compliance challenges to both prevent and respond to potential violations.

Our team brings together decades of experience as in-house compliance professionals, former senior regulators and law enforcement professionals, internal auditors, and technology specialists.

Proactive Compliance Services
  • Global Compliance Training Design & Delivery
  • Global Enhanced Due Diligence (EDD) Support
  • Global Sanctions Enterprise Risk Assessment & Modeling
  • Internal Compliance Audit Co-Sourcing
  • Sanctions Compliance Data Rationalization & Enhancement
  • Sanctions Compliance Investigations
  • Sanctions Compliance Program Assessment & Operational Design
  • Sanctions Compliance Technology Consulting & Implementation
  • Transaction Risk Model Design
Incident Response
  • De-Listing Petitions
  • Internal Investigations / Look-Back Exercises
  • Post-Settlement Compliance Monitorships
  • Program Remediation
OFAC SANCTIONS COMPLIANCE PROGRAM (SCP) OVERVIEW

In 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued detailed guidance setting expectations for an adequate Sanctions Compliance Program (SCP), which includes five essential components:

  • Management Commitment: Senior management must delegate sufficient authority and provide adequate resources to the compliance function to execute the program as designed.
  • Risk Assessment: The SCP should include a “holistic review” of the global organization to identify the scope and nature of its interactions with external entities.
  • Internal Controls: The SCP should include internal controls such as policies, procedures, regular audits, and adequate recordkeeping.
  • Testing & Auditing: The SCP should be tested by an audit function that is directly accountable to senior management, independent of the function being reviewed, and technically qualified to review the activities in its audit scope.
  • Training: The SCP should be communicated via a broadly accessible global training program that communicates job-specific sanction compliance responsibilities and evaluates compliance awareness.
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