Lessons From The OFAC Compliance Settlements With SAP And MoneyGram
It is essential to ensure that you implement proper IP address tracing protocol for any cloud-based services which may be used by someone in a foreign country. If you work with third-party vendors who engage with people in other countries, you must complete proper due diligence to ensure that they are not selling your services to people on an SDN list. If you do business with people from foreign countries, you must ensure that they are not blocked by the Department of the Treasury.
Finally, it is important to ensure that you have a proper Compliance and Audit team to ensure that you are able to audit your own systems and ensure that no violations are occurring.