INTERNATIONAL TRADE LAW
Sanctions Compliance Officer: Role & Checklist
A sanctions compliance officer is the person an exporter designates to own its OFAC compliance program — the one with the authority, resources, and independence to screen counterparties, set policy, train staff, and decide when to escalate. The title matters less than the mandate. What regulators look for is a clearly accountable person who can make sanctions decisions stick, not a job description filed away and forgotten.
This checklist explains where the role sits, what it actually does, and how those duties map onto the federal compliance framework exporters are measured against.
Why the role exists
The U.S. Treasury’s Office of Foreign Assets Control (OFAC) administers U.S. economic sanctions, and in 2019 it published A Framework for OFAC Compliance Commitments describing what an adequate program looks like. The Framework’s first essential component is management commitment — and a designated compliance officer is how a company demonstrates it. When OFAC weighs an enforcement case, the existence and quality of that compliance function is one of the factors it considers.
For a closer look at the agency itself, see what OFAC is and how it affects your business.
The authority the role needs
A compliance officer without authority is a liability, not a safeguard. To do the job, the role needs three things from senior management:
- Autonomy — the standing to halt a transaction or escalate a concern without being overruled for commercial convenience.
- Resources — screening tools, current sanctions lists, and enough staff time to actually run the checks.
- A direct line to leadership — sanctions risk is a board-level risk, and the officer should be able to reach senior management without a filter.
OFAC’s Framework treats senior-management support as foundational. A program staffed by someone with no budget and no clout fails the first test before it screens a single party.
The core duties checklist
The officer’s day-to-day work maps cleanly onto OFAC’s five essential compliance components. Use the table as a working checklist.
| OFAC compliance pillar | What the officer owns |
|---|---|
| Management commitment | Holds the designated mandate; reports sanctions risk to leadership; secures budget and tools |
| Risk assessment | Maps exposure across customers, destinations, products, and intermediaries; refreshes it as the business changes |
| Internal controls | Sets screening procedures, written policies, and escalation paths; applies the 50 Percent Rule to ownership checks |
| Testing and auditing | Commissions independent reviews; fixes gaps; tracks remediation to closure |
| Training | Makes sure the right people are trained and that attendance is documented |
Two duties deserve emphasis because they are where programs most often fail. Screening has to test parties against the live Specially Designated Nationals and Blocked Persons (SDN) List and account for indirect ownership — an entity owned 50% or more, in the aggregate, by blocked persons is itself blocked even if it is not separately listed. Escalation has to be real: a documented path for a salesperson to flag a possible match and get a fast, recorded decision.
Recordkeeping the officer must enforce
The officer is responsible for the records that prove the program works. OFAC’s recordkeeping rule now requires covered transaction records to be kept for ten years — extended from five effective March 12, 2025, to track the longer statute of limitations for sanctions violations (31 CFR 501.601). Screening logs, license determinations, training rosters, and escalation decisions all fall within that retention window.
How the role connects to the rest of the program
The compliance officer does not work alone. The role sits at the center of a set of documents and routines that each carry their own checklist:
- The policies and procedures that put the program in writing.
- The training program that operationalizes it across the workforce.
- The exam and audit readiness that tests whether it works.
- The incident response plan for when something slips through.
If your business touches restricted destinations or counterparties, the practice area page for international trade law explains how counsel supports the function.
Frequently asked questions
Does every exporter need a full-time sanctions compliance officer? No. The role should be sized to the risk. A smaller exporter may assign the mandate to an existing manager or rely on outside counsel for the harder calls; a high-volume exporter shipping to higher-risk markets needs dedicated capacity. What matters is that one accountable person clearly owns it.
What happens if there’s no designated officer and a violation occurs? The absence of a functioning compliance program is a factor that can aggravate an OFAC enforcement outcome, while a credible program can mitigate it. Civil sanctions liability is generally strict, so “no one was in charge” is not a defense — it is a problem.
Can the role be outsourced? Screening tools and legal advice can be outsourced, but accountability cannot. A company can hire vendors and counsel, yet it remains responsible for its own compliance and should keep an internal owner who can direct the work and make decisions.
Standing up or strengthening a sanctions compliance function? Reidel Law Firm’s flat-fee import/export compliance memo gives your compliance officer a clear, plain-English read on where the real exposure sits — with direct attorney access. Get an import/export compliance memo →
