1. Develop a comprehensive sanctions policy.
Your sanctions policy should be tailored to your business and should include a description of the prohibited activities, a list of sanctioned countries and entities, and procedures for employees to follow when conducting transactions.
2. Conduct risk assessments.
You should regularly assess the risks associated with your business activities and identify any areas that may be at risk of violating sanctions.
3. Create and maintain an up-to-date list of sanctioned entities.
You should maintain a list of all sanctioned entities and update it regularly as new entities are added to the sanctions list.
4. Train employees on sanctions compliance.
Employees should be trained on what activities are prohibited by sanctions, how to identify sanctioned entities, and what procedures to follow when conducting transactions.
5. Implement procedures for reviewing transactions against OFAC lists
All transactions should be screened against OFAC's sanction lists to ensure compliance.
6. Implement procedures for requesting OFAC approvals.
If you need approval from OFAC before proceeding with a transaction, you should have procedures in place for requesting and obtaining such approvals.
7. Maintain records of transactions and reviews.
You should keep records of all transactions that are conducted as well as reviews of those transactions conducted by employees.
8. Report any suspicious activity to OFAC or the relevant authorities.
If you suspect that someone is engaged in illegal activity related to sanctions, you should report it to OFAC or the appropriate authorities.
9. Monitor changes to sanctions regulations and adjusts compliance accordingly.
You must keep up with changes to sanctions regulations and make any necessary adjustments to your compliance program to ensure continued compliance.
10. Review internal processes regularly for continued compliance with OFAC rules.
You should review your internal processes regularly to ensure that they are still in compliance with OFAC's rules.