The Case for Building a Robust Sanction Compliance Program

Organizations must do due diligence to navigate a complicated web of sanctions—and it’s not just banks and financial institutions that are subject to the sanctions. Increasingly, companies across various industries have been the target of enforcement actions, most notably by the U.S. Department of the Treasury’s Office of Foreign Asset Control (OFAC), which aggressively pursues sanctions violations by U.S. companies, as well as by foreign companies if they are publicly-traded in the U.S., or if any U.S. person is involved.