Quick Reference: The Five SCP Components at Your Fingertips
Recall the five OFAC SCP components and how to use them during program diagnosis.
Recall What are the five OFAC SCP components? Management commitment, risk assessment, internal controls, testing and auditing, and training. Use them as a diagnostic loop whenever a sanctions issue appears. Compare Screening tool versus sanctions program A vendor can support controls, but it cannot be the whole program. Objection Leadership says, "We have never had a sanctions issue, so why add testing?" Use when testing budget is challenged. Your line Testing is how we know whether the absence of issues means effective controls or simply undetected gaps. Do not argue from fear. Tie testing to evidence and control assurance. The…
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