OFAC encourages anyone who may have violated OFAC-administered sanctions programs, or anyone who is aware of potential violations, to disclose the apparent or potential violation to OFAC. Voluntary self-disclosure to OFAC is considered a mitigating factor by OFAC in enforcement actions, and pursuant to OFAC’s Economic Sanctions 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. OFAC’s Economic Sanctions Enforcement Guidelines explain what constitutes a voluntary self-disclosure for purposes of receiving 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.
Please review OFAC’s Production Submission Standards, which detail OFAC’s preferred technical standards for formatting electronic document productions.
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. Such disclosure may also support credit for cooperation. 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. Please see OFAC’s Economic Sanctions Enforcement Guidelines and OFAC’s Framework for OFAC Compliance Commitments for additional information regarding voluntary self-disclosures and other mitigating factors, as well as OFAC’s general framework for the enforcement of its sanctions programs. For more information on OFAC’s enforcement process and self-disclosing violations, please see the Civil Penalties and Enforcement Information page on OFAC’s website.
Other U.S. government agencies, including the U.S. Department of Justice (DOJ) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) have their own disclosure procedures for voluntarily self-disclosing violations of U.S. sanctions and export control laws. Moreover, 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.
Date Updated: August 21, 2024.