To reiterate the importance of compliance, FinCEN, an agency within the US Department of Treasury, issued a 2014 Advisory to US Financial Institutions on Promoting a Culture of Compliance. Most of FinCEN’s suggestions to promote a culture of Bank Secrecy Act compliance at financial institutions can equally apply to promoting a culture of OFAC compliance in any number of businesses. For a sanctions compliance program to be effective, it is considered best practices that it has demonstrable support from the firm’s leadership. Boards of directors and senior management should set the tone for the organization by creating a culture of compliance. To comply with economic sanctions, key personnel should receive ongoing sanctions compliance training and be familiar with requirements and prohibitions and understand the potential impact that violations can have on the firm.

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