OFAC encourages anyone who is aware of possible violations of OFAC-administered sanctions to report them to OFAC through OFAC's Disclosure Portal. In considering any enforcement action, OFAC looks at the totality of the circumstances surrounding any possible violation, including whether a matter was voluntarily self-disclosed. OFAC considers voluntary self-disclosure a mitigating factor that, pursuant to OFAC's Economic Sanctions Enforcement Guidelines, may result in a reduction in the base amount of any possible civil penalty. Benefits may also include a greater likelihood of avoiding a financial penalty.
OFAC's Enforcement Guidelines explain what constitutes a voluntary self-disclosure for purposes of receiving a reduction in the base penalty or penalty mitigation. Among other factors, the guidelines state that, in addition to notification of an apparent violation, a voluntary self-disclosure must include, or be followed within a reasonable period of time by, a report of sufficient detail to afford OFAC a complete understanding of an apparent violation's circumstances. When such a report is not included with an initial notification, OFAC will generally expect such a report within 180 days after the initial notification. A voluntary self-disclosure also may evidence the extent of an organization's cooperation — an important factor OFAC considers in determining the appropriate enforcement response.
All submissions to the Disclosure Portal should conform to OFAC's Production Submission Standards, which detail OFAC technical standards for formatting electronic document production.
For resources related to OFAC enforcement, please see OFAC's Civil Penalties and Enforcement Information page. For information on an effective sanctions compliance program, see OFAC's Framework for OFAC Compliance Commitments.
In addition, the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) maintains a whistleblower incentive program for violations of OFAC-administered sanctions, in addition to violations of the Bank Secrecy Act. Individuals located in the United States or abroad who provide information may be eligible for awards if the information they provide leads to a successful enforcement action that results in monetary penalties exceeding $1,000,000. The U.S. Department of Justice (DOJ) and the U.S. Department of Commerce's Bureau of Industry and Security (BIS) also maintain their own disclosure programs, including for violations of U.S. sanctions and export controls laws.