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Senior management buy-in is a must

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Question: 
OFAC released a guidance document titled “A Framework for OFAC Compliance Commitments.” What does this guidance emphasize that is arguably the most critical commitment for a successful Sanctions Compliance Program?
Answer: 

“Senior Management’s commitment to, and support of, an organization’s risk-based SCP is one of the most important factors in determining its success. This support is essential in ensuring the SCP receives adequate resources and is fully integrated into the organization’s daily operations, and also helps legitimize the program, empower its personnel, and foster a culture of compliance throughout the organization.”

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First published on 01/31/2021

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