“The Office of Foreign Assets Control (OFAC), an agency of the U.S. Department of the Treasury, administers and enforces U.S. economic sanctions programs against targeted foreign governments, individuals, groups and entities in accordance with national security and foreign policy. OFAC had not previously published guidance addressing essential elements for an effective sanctions compliance program (SCP). It has now done so. Specifically, on May 2, 2019, OFAC published such guidance, entitled “ A Framework for OFAC Compliance Commitments ” (OFAC Framework).”