A Canadian-based travel technology company retained StoneTurn to assist in developing a sanctions/OFAC compliance program. Leveraging OFAC’s guidance for risk-based Sanctions Compliance Programs, StoneTurn assisted the client in performing a high-level sanctions risk assessment and developed recommendations to enhance the client’s compliance program based on OFAC’s five essential components of compliance: (1) management commitment; (2) risk assessment; (3) internal controls; (4) testing and auditing; and (5) training. StoneTurn also assisted the company in drafting a global Sanctions Compliance Policy.