Hi everyone, I have a question about OFAC (Office of Foreign Assets Control) compliance. I represent a small company that has started operating internationally, and we are just now realizing how important and complex OFAC sanctions compliance can be.
I would like to know where to begin the process of setting up a system to comply with these requirements? What are the key points to consider to minimize the risks of violating sanctions regimes? How often should you conduct internal audits and reviews for compliance with the sanctions lists? And, of course, how useful is it to engage third-party consultants to create an effective OFAC compliance system?
I would be grateful for any advice or recommendations, especially if someone has already gone through this process and can share their experience. How do you deal with these issues in your company?
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The best place to start is with a detailed understanding of those areas of your business that may be exposed to sanctions risks. The key steps, in my opinion, are regular checks of counterparties and partners against the sanctions lists and the implementation of a transaction monitoring system. In some cases, it is really better to engage a third-party consultant to help avoid mistakes. By the way, I found a useful article on this topic the other day - it describes the main mistakes and root causes of OFAC compliance violations that are worth considering. You can read it here https://www.jdsupra.com/legalnews/ofac-compliance-avoiding-common-root-7179583/ . I hope it will help you get your bearings!