Key Components of a Strong Sanctions Compliance Program
Abrigo
JUNE 14, 2021
As seldom seen from the regulatory authorities, the Guidelines generally defines management as senior leadership, executives, or the board of directors. Common root causes include: Lack of a formal OFAC SCP Misinterpretation or failure to understand OFAC regulations Facilitating transactions by non-U.S. BSA Rules and Regulation.
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