companies should generally conduct a holistic review of the entire company and assess where it has external exposure. This allows for the identification of potential areas of interaction with OFAC-prohibited persons, parties, ...
Account or Payable-Through Account Sanctions (CAPTA List):The CAPTA List identifies foreign financial institutions subject to correspondent account or payable-through account sanctions due to their involvement in facilitating significant transactions for designated individuals, entities, or countries. ...
While each risk-based SCP will vary depending on a variety offactors-including the company's size and sophistication, products and services,customers and counterparties, and geographic locations-each program should bepredicated on and incorporate at least five essential components of compliance: (1) m...
When applying the Guidelines to a given factual situation, OFAC will consider favorably subject persons that had effective SCPs at the time of an apparent violation. For example, under General Factor E (compliance program), OFAC may consider the existence, nature, and adequacy of an SCP. and ...