Office of Foreign Assets Control Risk Assessment

Gain insight into how to evaluate risks posed by parties, transactions, and entire lines of business.

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 (1) how individual departments and product lines might be exposed to sanctions risk, (2) how to identify high-risk transactions and parties, and (3) 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. For example, OFAC's sanctions now country-based embargoes, lists of prohibited parties, sectoral sanctions with transaction-specific restrictions, as well as numerous general licenses that authorize certain activity with a sanctions nexus. 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. Moreover, this topic will cover specific issues concerning financial transactions with a historically high-risk of sanctions exposure. As OFAC continues to raise its standards for compliance practices, this information is critical for businesses to ensure that their SCP meets the new requirements and mitigates unnecessary risks across their organizations.