May 13, 2019

DOJ and OFAC recently published new guidance documents outlining essential components of compliance programs and how each agency would consider such programs during an investigation of apparent violations. DOJ’s guidance updates a prior version, and in issuing the guidance, DOJ noted that the “document is part of [its] broader efforts in training, hiring, and enforcement to help promote corporate behaviors that benefit the American public and ensure that prosecutors evaluate the effectiveness of compliance in a rigorous and transparent manner.” OFAC’s guidance marks the first time that OFAC has provided explicit guidance on what it views as the effective elements of a sanctions compliance program, and it includes an appendix outlining several of the root causes that have led to sanctions violations.

For more information on how this could impact your business, contact:

  • Martin Lutz, Partner (, 512-495-6024)
  • Lindsey Roskopf, Attorney (, 713-615-8534)
  • or another member of the McGinnis Lochridge International Trade and Transactions Practice Group
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