6 Key Takeaways: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC)

On May 2, 2019, OFAC released a detailed statement of its views on the best practices that companies should follow to ensure compliance with U.S. sanctions laws and regulations. The document is called “A Framework for OFAC Compliance Commitments” (OFAC Framework), and serves as a roadmap for not only preventing sanctions violations but also, when violations do occur, providing transparency as to how OFAC will assess the adequacy of a company’s existing compliance program in determining what penalty to impose.

6 Key Takeaways from the OFAC Framework

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Knowledge assets are defined in the study as confidential information critical to the development, performance and marketing of a company’s core business, other than personal information that would trigger notice requirements under law. For example,
The new study shows dramatic increases in threats and awareness of threats to these “crown jewels,” as well as dramatic improvements in addressing those threats by the highest performing organizations. Awareness of the risk to knowledge assets increased as more respondents acknowledged that their