The General Electric Company, e.l.f. Cosmetics, Expedia, Atradius Trade Credit Insurance and Stanley Black and Decker are in a special club.
All of these organizations have paid civil penalties in 2019 for sanctions violations. Individual settlements ranged from $325,000 to $2.7 million are all part of $1.28 billion in civil penalties levied by OFAC so far this year.
So no. You do not want to join that club. (And you don’t even want to know about the club of criminal violators.)
How do you avoid the club? Well, for help, in June of 2019 the Department of the Treasury issued guidance on how to create a framework for an effective sanctions compliance program. (See InvoiceInfo’s OFAC Publishes Guidance for Sanctions Compliance Framework.)
Now attorney and compliance expert Thomas Fox has written a series of articles providing additional guidance in setting up a good compliance program. Fox, who is a “compliance evangelist,” has published The OFAC Compliance Framework in three parts (plus an introduction that includes a tribute to legendary drummer Ginger Baker — check it out!) through JD Supra.
The three parts, or elements, are:
- The OFAC Compliance Framework: Element 1 – Management Commitment
- The OFAC Compliance Framework: Element 2 – Risk Assessment
- The OFAC Compliance Framework: Element 3 – Internal Controls
If you haven’t gotten far in your compliance efforts, or you want to review your efforts, these may help. As the fines noted above indicate, sanction compliance is not an inconsequential matter.
Regarding the challenge of regular list checks and review of your organization’s customers and vendors, InvoiceInfo and VendorInfo can help. Lists can be and are updated any time, as required by events and changing policies. Clients’ lists are reviewed daily in order to ensure no update of either the government sanction lists or clients’ customer or vendor lists gets missed. Talk to us.
And if you want to read about Ginger Baker, who really belonged to an exclusive club, see Farewell to Ginger Baker and Welcome to the OFAC Compliance Framework.
Vendor checks against sanction lists are an important part of a sanctions compliance program. To learn how VendorInfo can help with your sanctions compliance program, click here to request more information or call (678) 335-5735.