Compliance Monitoring
Compliance monitoring is the ongoing process of checking that controls are working — not just that they exist. An export compliance program that ran clean in January can have gaps by March if a new Entity List addition isn't caught, a license exception condition changes, or a counterparty's ownership structure shifts after an SDN designation. We've seen companies with solid onboarding screening miss mid-contract designations because their monitoring cadence was quarterly. OFAC's enforcement guidance is explicit: reasonable compliance programs include ongoing monitoring, not just point-in-time checks. We cover screening frequency standards, automated alert triggers, periodic program reviews, and the internal audit schedule that holds up in a voluntary self-disclosure.