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Podcast: Corruption Crime & Compliance
Episode: Episode 94 -- How to Conduct a Sanctions Compliance Risk Assessment
Description:
OFAC’s new framework guidance for sanctions compliance programs stretched into new territory with its risk assessment requirement. This new approach reflects OFAC’s recent aggressive enforcement programs.
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The scope of a risk assessment has to mirror the breadth of enforcement risks and has to include review of:
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(i) customers, supply chain, intermediaries, and counter-parties;
(ii) the products and services it offers, including how and where such items fit into other financial or commercial products, services, networks or systems;
(iii) the geographic locations of the organi...