OFAC's framework describes five essential components of a sanctions compliance programme: management commitment, risk assessment, internal controls, testing and auditing, and training. It is guidance about how an organisation can organise compliance around its actual exposure, rather than a new sanctions designation or a universal checklist of prohibited transactions.

Risk assessment considers customers, counterparties, products, services, supply chains and geographic exposure. Internal controls translate that assessment into screening, escalation, decision-making and remediation. Management support, adequate resources and a culture that allows concerns to be raised are necessary for those controls to work in practice.

Testing and training close the loop by revealing weaknesses and helping staff recognise relevant risks. The framework also discusses root causes of sanctions violations, such as inadequate ownership analysis or failures after business changes. Its practical value is to connect operational controls to a documented assessment of the organisation's sanctions exposure and to make improvement continuous.