Is Your Sanctions Compliance Program Compliant? — A Quick Five-Question Quiz
Here are five (5) questions that are fairly simple but revealing as to whether a company’s Sanctions Compliance Program (“SCP”) is effective. This is not an exhaustive list but it is my top 5. Question 1 — Does the Company conduct annual sanctions compliance training for relevant employees? I have written about this and reminder everyone since 2019 about the importance of conducting sanctions training. OFAC’s Sanctions Compliance Guidance issued in 2019 mandates, at a minimum, that companies provide annual sanctions compliance training. Notwithstanding this directive, which is reinforced by compliance professionals (including me), most companies are not offering annual sanctions compliance training. I cannot understand why companies are ignoring this requirement. Several States require annual training on sexual harassment and other topics. Companies are able to meet this requirement, but when it comes to sanctions compliance, companies lack the commi...