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Office of Foreign Assets Control Risk Assessment

Office of Foreign Assets Control Risk Assessment

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This topic helps persons at the C-Suite, department management, and transaction review levels understand how to evaluate risks posed by parties, transactions, and entire lines of business. In addition, the material explains how companies can identify measures to mitigate sanctions risk at systemic and transaction-specific levels.

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    On May 2, 2019, the Office of Foreign Assets Control (OFAC) released new guidance stating that holistic sanctions risk assessments must be a part of a company’s Sanctions Compliance Program (SCP) for the SCP to qualify as a mitigating factor in enforcement decisions. These risk assessments require banks and businesses to understand how individual departments and product lines might be exposed to sanctions risk, how to identify high-risk transactions and parties, and which of these risks can be addressed with appropriate controls. Yet, many banks and businesses continue to rely on processes that do not reflect the diverse range of sanctions programs and measures in place today.
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