A sanctions compliance program (SCP) is a documented set of policies, controls, and training that keeps your company from doing business with parties the U.S. government has blocked. The Office of Foreign Assets Control (OFAC) enforces U.S. economic sanctions on a strict-liability basis — you can be penalized for a prohibited transaction even if you never knew the other side was sanctioned. A real program is the difference between a defensible mistake and an indefensible one. This guide builds one around the five components OFAC itself uses to judge them.

Watch — Elements of a Sanctions Compliance Program:

Why a program matters: strict liability

OFAC administers sanctions under the International Emergency Economic Powers Act (IEEPA) and related authorities, and it can impose civil penalties without proving you intended to break the law. The statutory maximum civil penalty is the greater of an inflation-adjusted cap (raised each year) or twice the value of the transaction, per violation — and a single shipment can generate many violations. Good faith does not excuse the viol