LFIs should take appropriate steps to develop, implement and regularly update an appropriate Sanctions Compliance Program (SCP) in order to fulfil their obligation to comply with the provisions of the Cabinet Decision 74 as well as with the directives of the relevant competent authorities and supervisory authorities in regard to sanctions issued by the UNSC. An appropriate SCP also assists LFIs to manage their exposure to the risks associated with international financial sanctions programs and restrictive measures implemented by other countries.

LFIs should design and update their SCP so that its scope is proportionate to the level of their risk profile, tailored to their nature, scale, and complexity, appropriate for the products and services they offer, the customers, clients, and partner relationships they maintain, and the geographic regions in which they operate. LFIs should ensure the SCP includes the eight (8) essential components: senior management commitment, risk assessment, sanctions risk appetite, internal controls, policies and procedures, training, independent audit and testing of processes and systems, and record keeping.