Describe the five essential components of an OFAC sanctions compliance program and how they connect.
The five SCP components are a loop, not a checklist. Management commitment gives authority. Risk assessment finds exposure. Internal controls turn risk into required actions. Testing and auditing check whether those actions work. Training turns the rules into decisions made outside the compliance team. The pieces rely on each other. A screening control without management backing can be overridden. A risk assessment without testing goes stale. Training without updated controls teaches old behavior. Testing without remediation creates repeat findings. How to use the model When a sanctions issue appears, ask which component failed. Was the business model never risk-assessed? Was…
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