US OFAC Sanctions Compliance Framework
The US Office of Foreign Assets Control (OFAC), within the Treasury Department, administers and enforces economic and trade sanctions programmes. OFAC published its Framework for Compliance Commitments (2019) outlining the five essential components of an effective sanctions compliance programme. Sanctions programmes include the Specially Designated Nationals (SDN) List, sectoral sanctions, and comprehensive country embargoes. OFAC sanctions have significant extraterritorial reach through secondary sanctions. Violations can result in civil penalties up to $330,000+ per violation or criminal penalties up to $20M and 30 years imprisonment.
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Framework Domains (14)
Internal Controls
| Code | Title |
|---|---|
| IC-1 | Policies and Procedures |
| IC-2 | Transaction Screening |
| IC-3 | Interdiction and Escalation |
| IC-4 | Recordkeeping |
| OFAC-SCP-3.1 | Sanctions Screening of Customers and Transactions |
| OFAC-SCP-3.2 | Transaction Interdiction and Blocking |
| OFAC-SCP-3.3 | Country and Comprehensive Sanctions Controls |
| OFAC-SCP-3.4 | Sectoral Sanctions Identification and Controls |
| OFAC-SCP-3.5 | Licensing and General License Management |
| OFAC-SCP-3.6 | Recordkeeping |
Internal Controls
| Code | Title |
|---|---|
| IC-1 | Policies and Procedures |
| IC-2 | Transaction Screening |
| IC-3 | Interdiction and Escalation |
| IC-4 | Recordkeeping |
| OFAC-SCP-3.1 | Sanctions Screening of Customers and Transactions |
| OFAC-SCP-3.2 | Transaction Interdiction and Blocking |
| OFAC-SCP-3.3 | Country and Comprehensive Sanctions Controls |
| OFAC-SCP-3.4 | Sectoral Sanctions Identification and Controls |
| OFAC-SCP-3.5 | Licensing and General License Management |
| OFAC-SCP-3.6 | Recordkeeping |
Management Commitment
| Code | Title |
|---|---|
| 2.1.1 | Requirement 2 policies and procedures |
| 2.1.2 | Roles and responsibilities for Requirement 2 |
| 2.1.3 | Food Safety and Quality Culture |
| 2.1.4 | Management Review |
| MC-1 | Senior Management Support |
| MC-2 | Compliance Culture |
| MC-3 | Dedicated Compliance Officer |
| MC-4 | Resource Allocation |
| OFAC-SCP-1.1 | Senior Management Commitment to Sanctions Compliance |
| OFAC-SCP-1.2 | Sanctions Compliance Officer Appointment |
Management Commitment
| Code | Title |
|---|---|
| 2.1.1 | Requirement 2 policies and procedures |
| 2.1.2 | Roles and responsibilities for Requirement 2 |
| 2.1.3 | Food Safety and Quality Culture |
| 2.1.4 | Management Review |
| MC-1 | Senior Management Support |
| MC-2 | Compliance Culture |
| MC-3 | Dedicated Compliance Officer |
| MC-4 | Resource Allocation |
| OFAC-SCP-1.1 | Senior Management Commitment to Sanctions Compliance |
| OFAC-SCP-1.2 | Sanctions Compliance Officer Appointment |
Program Management
| Code | Title |
|---|---|
| OFAC-SCP-9.1 | Sanctions Program Continuous Improvement |
Reporting
| Code | Title |
|---|---|
| OFAC-SCP-6.1 | Voluntary Self-Disclosure Process |
| OFAC-SCP-8.2 | Management Information and Metrics |
Risk Assessment
| Code | Title |
|---|---|
| COSO-IC-ERM-ST | Strategy and objective-setting - aligning risk appetite with strategy and formulating business objectives (ERM Framework integration) |
| COSO-IC-RA-06 | The organization specifies objectives with sufficient clarity for risk identification and assessment |
| COSO-IC-RA-07 | The organization identifies risks to objectives across the entity and analyzes them for management |
| COSO-IC-RA-08 | The organization considers the potential for fraud in assessing risks |
| COSO-IC-RA-09 | The organization identifies and assesses changes that could significantly impact internal control |
| DMF-4.1 | Impact Assessment |
| DMF-4.2 | Risk Categorization |
| DMF-4.3 | Regulatory Risk Assessment |
| OFAC-SCP-2.1 | Enterprise Sanctions Risk Assessment |
| OFAC-SCP-2.2 | Customer and Counterparty Due Diligence |
| RA-1 | Policy and Procedures |
| RA-2 | Security Categorization |
| RA-3 | Risk Assessment |
| RA-4 | Rule of Law Assessment |
| RA-5 | Vulnerability Monitoring and Scanning |
Risk Assessment
A dynamic and iterative process for identifying and assessing risks to the achievement of objectives, forming the basis for determining how risks should be managed.
| Code | Title |
|---|---|
| COSO-IC-ERM-ST | Strategy and objective-setting - aligning risk appetite with strategy and formulating business objectives (ERM Framework integration) |
| COSO-IC-RA-06 | The organization specifies objectives with sufficient clarity for risk identification and assessment |
| COSO-IC-RA-07 | The organization identifies risks to objectives across the entity and analyzes them for management |
| COSO-IC-RA-08 | The organization considers the potential for fraud in assessing risks |
| COSO-IC-RA-09 | The organization identifies and assesses changes that could significantly impact internal control |
| DMF-4.1 | Impact Assessment |
| DMF-4.2 | Risk Categorization |
| DMF-4.3 | Regulatory Risk Assessment |
| OFAC-SCP-2.1 | Enterprise Sanctions Risk Assessment |
| OFAC-SCP-2.2 | Customer and Counterparty Due Diligence |
| RA-1 | Policy and Procedures |
| RA-2 | Security Categorization |
| RA-3 | Risk Assessment |
| RA-4 | Rule of Law Assessment |
| RA-5 | Vulnerability Monitoring and Scanning |
Technology
| Code | Title |
|---|---|
| OFAC-SCP-8.1 | Technology and Data Governance |
Testing and Audit
| Code | Title |
|---|---|
| OFAC-SCP-4.1 | Independent Testing and Audit |
| OFAC-SCP-4.2 | Issue Identification and Root Cause Analysis |
Testing and Auditing
| Code | Title |
|---|---|
| TA-1 | Independent Testing |
| TA-2 | Sample Testing |
| TA-3 | Remediation of Findings |
Third Party Risk
| Code | Title |
|---|---|
| OFAC-SCP-7.1 | Third Party and Intermediary Oversight |
| OFAC-SCP-7.2 | Mergers and Acquisitions Sanctions Due Diligence |
Training
| Code | Title |
|---|---|
| OFAC-SCP-5.1 | Sanctions Training Program |
| OFAC-SCP-5.2 | Senior Management and Board Training |
| TR-1 | Periodic Training Program |
| TR-2 | Job-Specific Training |
| TR-3 | Accountability for Training |
| TR-4 | Training Updates |
| TRN-1 | Skills Development |
| TRN-2 | Local Workforce Training |
| TRN-3 | Participation in Training Programs |
Training
| Code | Title |
|---|---|
| OFAC-SCP-5.1 | Sanctions Training Program |
| OFAC-SCP-5.2 | Senior Management and Board Training |
| TR-1 | Periodic Training Program |
| TR-2 | Job-Specific Training |
| TR-3 | Accountability for Training |
| TR-4 | Training Updates |
| TRN-1 | Skills Development |
| TRN-2 | Local Workforce Training |
| TRN-3 | Participation in Training Programs |
Your Compliance Coverage
If you comply with US OFAC Sanctions Compliance Framework, you already cover:
SQF Code Edition 9 - Safe Quality Food
18%
10 controls mapped
Compare →EU AI Act
16%
9 controls mapped
Compare →ILO Tripartite Declaration of Principles concerning Multinational Enterprises (MNE Declaration)
16%
9 controls mapped
Compare →+ 625 more: NIST SP 800-53 Rev 5 (16%), NIS2 Directive (16%)
See all 628 mapped frameworks ↓Maps to 628 other frameworks
Frequently Asked Questions
What is US OFAC Sanctions Compliance Framework?
US OFAC Sanctions Compliance Framework is a compliance framework from United States (Treasury/OFAC) with 14 domains and 55 controls. The US Office of Foreign Assets Control (OFAC), within the Treasury Department, administers and enforces economic and trade sanctions programmes. OFAC published its Framework for Compliance Commitments (2019) outlining the five essential components of an effective sanctions compliance programme. Sanctions programmes include the Specially Designated Nationals (SDN) List, sectoral sanctions, and comprehensive country embargoes. OFAC sanctions have significant extraterritorial reach through secondary sanctions. Violations can result in civil penalties up to $330,000+ per violation or criminal penalties up to $20M and 30 years imprisonment. It is used by organisations to establish and maintain compliance with industry standards and regulatory requirements.
How many controls does US OFAC Sanctions Compliance Framework have?
US OFAC Sanctions Compliance Framework has 55 controls organised across 14 domains. The largest domains are Risk Assessment (13 controls), Management Commitment (8 controls), Training (7 controls). Each control defines specific requirements that organisations must implement to achieve compliance.
What frameworks does US OFAC Sanctions Compliance Framework map to?
US OFAC Sanctions Compliance Framework maps to 628 other compliance frameworks. The top mapping partners are SQF Code Edition 9 - Safe Quality Food (18% coverage), EU AI Act (16% coverage), ILO Tripartite Declaration of Principles concerning Multinational Enterprises (MNE Declaration) (16% coverage). Use our comparison tool to explore control-level mappings between frameworks.
How do I get started with US OFAC Sanctions Compliance Framework compliance?
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 55 controls and track your progress.
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