An effective training program is an integral component of a successful sanction compliance program. The training program should be provided to all employees and personnel periodically and generally should accomplish the following:
Provide job-specific knowledge based on need
Communicate the sanctions compliance responsibilities for employees
Hold employees accountable for sanctions compliance through assessments
Training Program
An adequate training program, tailored to an organization’s risk profile and all appropriate employees and stakeholders, is critical to the success of the compliance program. The organization commits to ensuring that its OFAC-related training program provides adequate information and instruction to employees and, as appropriate, stakeholders to support the organization’s compliance efforts. Such training should be further tailored to high-risk employees within the organization.
The organization commits to providing training with a scope that is appropriate for the products and services it offers; the customers, clients, and partner relationships it maintains; and the geographic regions in which it operates. It is committed in providing OFAC-related training with a frequency that is appropriate based on its OFAC risk assessment and risk profile.
The organization commits to ensuring that, upon learning of a confirmed negative testing result or audit finding, or other deficiency of its SCP, it will take immediate and effective action to provide training to or other corrective action to relevant personnel. The organization’s training program includes easily accessible resources and materials that are available to all applicable personnel.
Final Thoughts
A training program is a structured sequence and combination of activities designed to provide employees with the knowledge and skills they need to become better professionals. Each training program is designed to achieve specific business objectives. There may be various types of training programs available depending on the purpose.
