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US OFAC Sanctions Compliance Framework

United States
vFramework of May 2019 (guidance) with 31 CFR Part 501 as current to 23 September 2026
7 domains
31 controls

U.S. sanctions compliance as OFAC sets it: 'A Framework for OFAC Compliance Commitments' (May 2019), guidance describing five components of a risk-based sanctions compliance program (management commitment, risk assessment, internal controls, testing and auditing, training) that OFAC credits in enforcement but does not require, together with the binding recordkeeping and reporting rules of 31 CFR Part 501 (10-year records since March 2025; blocking, annual, unblocking and rejected transaction reports within set deadlines) and the Economic Sanctions Enforcement Guidelines.

Verified

US OFAC Sanctions Compliance Framework is a compliance framework from United States with 7 domains and 31 controls that map to 14 other frameworks. The largest domains are Internal controls (Framework, guidance) – US OFAC Sanctions Compliance Framework (7 controls), Recordkeeping and reporting (31 CFR Part 501, binding) – US OFAC Sanctions Compliance Framework (7 controls), Management commitment (Framework, guidance) – US OFAC Sanctions Compliance Framework (5 controls). Every control below carries what it requires and what an assessor expects to see.

Maintained by Gerard BlokdykVerified against the published standard Control text last updated

Framework summaries on this platform are interpretations grounded in the published source, for educational and compliance planning purposes. They do not reproduce or replace the official standards. Refer to the authoritative source for the definitive text. Framework names and trademarks belong to their respective organisations.

Framework Domains (7)

Enforcement Guidelines (31 CFR Part 501 Appendix A) – US OFAC Sanctions Compliance Framework

2 controls
Controls in the Enforcement Guidelines (31 CFR Part 501 Appendix A) – US OFAC Sanctions Compliance Framework domain of US OFAC Sanctions Compliance Framework: 2 controls
CodeTitle
us-ofac-sanctions-compliance-framework::501 App. A (III)Expect enforcement to weigh the General Factors: willfulness, awareness, harm, compliance program, remediation and cooperation
us-ofac-sanctions-compliance-framework::501 App. A (VSD)Consider voluntary self-disclosure: it halves the base penalty, but only if self-initiated, complete and authorised

Internal controls (Framework, guidance) – US OFAC Sanctions Compliance Framework

7 controls
Controls in the Internal controls (Framework, guidance) – US OFAC Sanctions Compliance Framework domain of US OFAC Sanctions Compliance Framework: 7 controls
CodeTitle
us-ofac-sanctions-compliance-framework::IC.IWrite clear SCP policies and procedures that reflect day-to-day operations
us-ofac-sanctions-compliance-framework::IC.IIImplement controls to identify, interdict, escalate and report prohibited activity, with calibrated and tested screening tools
us-ofac-sanctions-compliance-framework::IC.IIIEnforce SCP policies through internal or external audits
us-ofac-sanctions-compliance-framework::IC.IVAlign recordkeeping policies with OFAC requirements
us-ofac-sanctions-compliance-framework::IC.VOn learning of a control weakness, apply compensating controls until the root cause is fixed
us-ofac-sanctions-compliance-framework::IC.VICommunicate SCP policies to staff, high-risk gatekeepers and external parties performing SCP tasks
us-ofac-sanctions-compliance-framework::IC.VIIAppoint staff to embed SCP procedures into daily operations with business unit consultation

Management commitment (Framework, guidance) – US OFAC Sanctions Compliance Framework

5 controls
Controls in the Management commitment (Framework, guidance) – US OFAC Sanctions Compliance Framework domain of US OFAC Sanctions Compliance Framework: 5 controls
CodeTitle
us-ofac-sanctions-compliance-framework::MC.IHave senior management review and approve the sanctions compliance program
us-ofac-sanctions-compliance-framework::MC.IIGive the compliance unit authority, autonomy and a direct reporting line to senior management
us-ofac-sanctions-compliance-framework::MC.IIIResource the SCP: a dedicated sanctions compliance officer, qualified staff and adequate systems
us-ofac-sanctions-compliance-framework::MC.IVPromote a culture of compliance with speak-up without reprisal and SCP oversight of the whole organisation
us-ofac-sanctions-compliance-framework::MC.VTreat apparent violations and SCP failures seriously and fix their root causes systemically

Recordkeeping and reporting (31 CFR Part 501, binding) – US OFAC Sanctions Compliance Framework

7 controls
Controls in the Recordkeeping and reporting (31 CFR Part 501, binding) – US OFAC Sanctions Compliance Framework domain of US OFAC Sanctions Compliance Framework: 7 controls
CodeTitle
us-ofac-sanctions-compliance-framework::501.601Keep a full and accurate record of every transaction subject to OFAC rules for at least ten years
us-ofac-sanctions-compliance-framework::501.602Furnish complete information and documents to OFAC on demand, in OFAC's data format
us-ofac-sanctions-compliance-framework::501.603(b)(1)File an initial blocked property report within 10 business days of blocking
us-ofac-sanctions-compliance-framework::501.603(b)(2)File the Annual Report of Blocked Property by 30 September for holdings as of 30 June
us-ofac-sanctions-compliance-framework::501.603(b)(3)Report unblocked or transferred blocked property within 10 business days
us-ofac-sanctions-compliance-framework::501.604Report rejected transactions within 10 business days
us-ofac-sanctions-compliance-framework::501.605Notify OFAC of litigation, arbitration or ADR involving blocked persons or blocked property

Risk assessment (Framework, guidance) – US OFAC Sanctions Compliance Framework

2 controls
Controls in the Risk assessment (Framework, guidance) – US OFAC Sanctions Compliance Framework domain of US OFAC Sanctions Compliance Framework: 2 controls
CodeTitle
us-ofac-sanctions-compliance-framework::RA.IAssess OFAC risk across customers, supply chain, counterparties, products, transactions and geographies, including at onboarding and M&A
us-ofac-sanctions-compliance-framework::RA.IIUse a documented methodology to identify, analyse and address risks, updated from testing and audit findings

Testing and auditing (Framework, guidance) – US OFAC Sanctions Compliance Framework

3 controls
Controls in the Testing and auditing (Framework, guidance) – US OFAC Sanctions Compliance Framework domain of US OFAC Sanctions Compliance Framework: 3 controls
CodeTitle
us-ofac-sanctions-compliance-framework::TA.IKeep the testing or audit function independent, accountable to senior management and adequately resourced
us-ofac-sanctions-compliance-framework::TA.IIUse testing procedures matched to the SCP's sophistication that assess risk assessment and controls objectively
us-ofac-sanctions-compliance-framework::TA.IIIAct on confirmed negative test results with compensating controls until remediation

Training (Framework, guidance) – US OFAC Sanctions Compliance Framework

5 controls
Controls in the Training (Framework, guidance) – US OFAC Sanctions Compliance Framework domain of US OFAC Sanctions Compliance Framework: 5 controls
CodeTitle
us-ofac-sanctions-compliance-framework::TR.ITrain employees and relevant stakeholders, with tailored training for high-risk roles
us-ofac-sanctions-compliance-framework::TR.IIScope training to the products, customers, partners and regions of the business
us-ofac-sanctions-compliance-framework::TR.IIISet training frequency by risk, at a minimum annually
us-ofac-sanctions-compliance-framework::TR.IVRetrain or take corrective action with relevant staff after a negative finding or deficiency
us-ofac-sanctions-compliance-framework::TR.VKeep training resources easily accessible to all relevant personnel

Your Compliance Coverage

If you comply with US OFAC Sanctions Compliance Framework, you already cover:

Maps to 14 other frameworks

55 total controls
NIST SP 800-53 Rev 5
4 source controls mapped|1 target controls covered
7%
US ITAR and EAR - Export Control and Data Security
4 source controls mapped|1 target controls covered
7%
ISO/IEC 29147:2018
4 source controls mapped|1 target controls covered
7%
US Automated Commercial Environment (ACE) - CBP Trade Data Requirements
4 source controls mapped|1 target controls covered
7%
IAIS Insurance Core Principles (ICPs)
4 source controls mapped|1 target controls covered
7%
Sweden Data Protection Act (Dataskyddslag, 2018:218)
4 source controls mapped|1 target controls covered
7%
UAE Virtual Asset Regulatory Authority (VARA) Regulations
4 source controls mapped|1 target controls covered
7%
Uganda Data Protection and Privacy Act (2019)
4 source controls mapped|1 target controls covered
7%
Singapore Payment Services Act 2019
4 source controls mapped|1 target controls covered
7%
French Sapin II Law (Law No. 2016-1691)
1 source controls mapped|1 target controls covered
2%
ISO 22301:2019
1 source controls mapped|2 target controls covered
2%
ISO/IEC 23894:2023
1 source controls mapped|1 target controls covered
2%
EAR - Export Administration Regulations
1 source controls mapped|1 target controls covered
2%
US SBA SOP 50 10 8.1 Lender and Development Company Loan Programs
1 source controls mapped|1 target controls covered
2%

Coverage is not the same as your position

This page shows what US OFAC Sanctions Compliance Framework overlaps with in general. Where your organisation actually stands, against the standard you are going for and the certifications you already hold, is a different question. Same graph and the same recorded refutations, scoped to you rather than to a pair.

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What is US OFAC Sanctions Compliance Framework and who does it apply to?

US OFAC Sanctions Compliance Framework is a compliance framework from United States with 7 domains and 31 controls. U.S. sanctions compliance as OFAC sets it: 'A Framework for OFAC Compliance Commitments' (May 2019), guidance describing five components of a risk-based sanctions compliance program (management commitment, risk assessment, internal controls, testing and auditing, training) that OFAC credits in enforcement but does not require, together with the binding recordkeeping and reporting rules of 31 CFR Part 501 (10-year records since March 2025; blocking, annual, unblocking and rejected transaction reports within set deadlines) and the Economic Sanctions Enforcement Guidelines. It is used by organisations to establish and maintain compliance with industry standards and regulatory requirements.

What does US OFAC Sanctions Compliance Framework actually require?

US OFAC Sanctions Compliance Framework has 31 controls organised across 7 domains. The largest domains are Internal controls (Framework, guidance) – US OFAC Sanctions Compliance Framework (7 controls), Recordkeeping and reporting (31 CFR Part 501, binding) – US OFAC Sanctions Compliance Framework (7 controls), Management commitment (Framework, guidance) – US OFAC Sanctions Compliance Framework (5 controls). Each control defines specific requirements that organisations must implement to achieve compliance.

If I already comply with another framework, how much of US OFAC Sanctions Compliance Framework do I already cover?

US OFAC Sanctions Compliance Framework maps to 14 other compliance frameworks. The top mapping partners are NIST SP 800-53 Rev 5 (7% coverage), US ITAR and EAR - Export Control and Data Security (7% coverage), ISO/IEC 29147:2018 (7% coverage). Use our comparison tool to explore control-level mappings between frameworks.

How do I implement US OFAC Sanctions Compliance Framework?

Start your US OFAC Sanctions Compliance Framework compliance journey by running a self-assessment on our platform to identify your current compliance posture. Our AI advisory can answer specific questions about US OFAC Sanctions Compliance Framework requirements, and cross-framework mapping helps you leverage existing controls from other frameworks you may already comply with. Create a free account to access all 31 controls and track your progress.

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