The Australian Sanctions Office (“ASO”) has released a policy document outlining its approach to compliance and enforcement. The ASO’s policy states that it takes a “graduated, risk-based approach to compliance.”
In terms of enforcement, the risk-based approach categorizes enforcement activities into three tiers: low, medium and high. Low-risk issues are treated with remedial actions, and medium-risk ones have requirements for formal corrective actions, such as a corrective action plan and incre...
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