Yesterday, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) published ‘A Framework for OFAC Compliance Commitments’* in order to provide organizations subject to US jurisdiction, as well as foreign entities that conduct business in or with the United States or US persons, or that use US-origin goods or services, with a framework on the essential components of a sanctions compliance program (SCP). The document* also outlines how OFAC may incorporate these components into its assessment of apparent violations and resolution of investigations resulting in settlements. OFAC strongly encourages organizations to approach sanctions compliance using a risk-based analysis by developing and updating a SCP.