Is a compliance attestation legally required?

No single law mandates “attestations” by name, but OFAC expects an effective, risk-based compliance program, and attestations are a common, well-recognized way to document internal controls, training acknowledgment, and counterparty commitments.

Does a vendor attestation protect us if the vendor lies?

It helps but does not fully insulate you. An attestation evidences your diligence and shifts some responsibility, but you still need screening and monitoring — and you cannot rely on an attestation you have reason to doubt.

How often should attestations be renewed?

On a risk-based cadence. Many programs refresh employee and key third-party attestations annually, with additional attestations triggered by specific events such as onboarding a new vendor or clearing a high-risk transaction.

Who should sign sanctions attestations?

The people whose conduct the control depends on — employees in sensitive roles, third parties with sanctions exposure, and the managers accountable for controls in their area. Reidel Law Firm helps importers, exporters, and their counterparties build sanctions programs that hold up to scrutiny — including the attestations, screening, and stakeholder roles that make them credible. Our flat-fee import/export compliance memo gives you a written read on your program’s gaps. Learn more about our international trade law practice.

INTERNATIONAL TRADE LAW

Sanctions Compliance Attestation: What It Means

Schuyler 'Rocky' Reidel July 15, 2023 4 min read

A compliance attestation is a formal, signed statement in which someone — an employee, a vendor, a counterparty, or a manager — certifies that they understand the applicable sanctions rules and are following the company’s compliance controls. In sanctions compliance, an attestation turns a vague expectation (“everyone knows the rules”) into a docu