On May 2, 2019, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury published guidance (the “Guidance”) encouraging corporations subject to U.S. jurisdiction, as well as foreign entities that conduct business with U.S. persons, in or with the United States, or using U.S.-origin goods or services, to develop and employ risk-based sanctions compliance programs (“SCPs”) on the basis that such SCPs help corporations detect and prevent sanctions violations in their day-to-day operations and, when sanctions violations occur, help mitigate civil monetary penalties imposed by OFAC.
