OFAC encourages anyone who may have violated OFAC-administered regulations to disclose the apparent violation to OFAC voluntarily. Voluntary self-disclosure to OFAC is considered a mitigating factor by OFAC in enforcement actions, and pursuant to OFAC’s Enforcement Guidelines, will result in a reduction in the base amount of any proposed civil penalty.
Please submit all voluntary self-disclosures electronically to OFACDisclosures@treasury.gov. Unless the disclosure is an initial disclosure which will be supplemented with additional information, the submission should contain sufficient detail to afford OFAC a complete understanding of an apparent violation’s circumstances. Please review the Office of Compliance and Enforcement (“OCE”) Data Delivery Standards Guidance: Preferred Practices for Productions to OFAC, which details OFAC’s preferred technical standards for formatting electronic document productions submitted to OCE.
OFAC does not have an "amnesty" program. OFAC does, however, review the totality of the circumstances surrounding any apparent violation, including whether a matter was voluntarily self-disclosed to OFAC. OFAC will also consider the existence, nature, and adequacy of a subject person’s risk-based OFAC compliance program at the time of the apparent violation, where relevant, among other factors. Please see OFAC’s Enforcement Guidelines for additional information regarding voluntary self-disclosures and other mitigating factors, as well as the agency’s general framework for the enforcement of economic sanctions programs administered by OFAC.