12/03/19: In a post on The FCPA Blog, Richard Cassin does a public (and company) service by distilling Treasury Department’s Office of Foreign Assets Control’s recently published A Framework for OFAC Compliance Commitments....
In the post, Cassin zeros in on the Framework’s section about “… root causes of sanctions violations that OFAC found during actual investigations.” Helpfully, he “… shortened OFAC’s list by combining items and dropping others.” After reading Cassin’s post, compliance professionals in the area of sanctions compliance will want to go to OFAC’s full Framework, but this post is a great starting point for anyone dealing with corporate compliance...