Not as Close to the Vest: OFAC Releases a “Framework” for Sanctions Compliance that Offers a Glimpse into the Agency’s Enforcement Posture

For an agency not known to show its cards when it comes to enforcement priorities, the release by the Treasury Department's Office of Foreign Assets Control (OFAC) of "A Framework for OFAC Compliance Commitments" (the Framework) offers a rare, helpful glimpse into the agency's expectations around sanctions compliance.