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.
Framework summaries on this platform are AI-assisted interpretations 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 (5)
Internal Controls
| Code | Title |
|---|---|
| IC-1 | Policies and Procedures |
| IC-2 | Transaction Screening |
| IC-3 | Interdiction and Escalation |
| IC-4 | Recordkeeping |
Management Commitment
| Code | Title |
|---|---|
| 2.1.1 | Management Policy |
| 2.1.2 | Management Responsibility |
| 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 |
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 |
| RA-1 | Security Risk Assessment |
| RA-2 | Human Rights Risk Identification |
| RA-3 | Conflict Analysis |
| RA-4 | Rule of Law Assessment |
| RA-5 | Equipment Transfer Risk |
Testing and Auditing
| Code | Title |
|---|---|
| TA-1 | Independent Testing |
| TA-2 | Sample Testing |
| TA-3 | Remediation of Findings |
Training
| Code | Title |
|---|---|
| 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 |
Maps to 633 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 5 domains and 35 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 35 controls organised across 5 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 633 other compliance frameworks. The top mapping partners are SQF Code Edition 9 — Safe Quality Food (29% coverage), ILO Nursing Personnel Convention C149 (1977) (26% coverage), ILO Tripartite Declaration of Principles concerning Multinational Enterprises (MNE Declaration) (26% 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 35 controls and track your progress.
Start Your Compliance Journey
Create a free account to run self-assessments, get AI advisory, and track your compliance progress across 692 frameworks.
Get Started Free →Free forever — no credit card required