A compliance program is not just for big banks anymore - it is becoming a standard requirement for anyone doing international business. It usually includes a written policy, verification tools to screen your partners, and regular audits. You can find a breakdown of what a "risk-minimizing compliance strategy" looks like on https://ofacblockedfundslawyers.com/. It doesn't have to be a whole department; for a mid-sized firm, it can be a set of procedures that your existing team follows. The key is to show that you are making a "good faith" effort to avoid prohibited transactions. I've seen companies that ignored this get hit with fines that were ten times the cost of a compliance program. My advice is to get a professional to help you set it up correctly the first time. It's an investment in your company's survival in the global market.

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