The Treasury Department’s Office of Foreign Assets Control has launched a new Voluntary Self-Disclosure Portal for submitting voluntary self-disclosures of potential violations of OFAC-administered sanctions programs. OFAC states that by transitioning to this online system it aims to increase efficiency and transparency for persons submitting information and to enable faster acknowledgment of submissions, clearer communication throughout the review process, and a more user-friendly experience overall.
OFAC considers VSDs to be a mitigating factor when determining the appropriate enforcement action to take in response to a particular case. Additionally, when a civil monetary penalty is warranted, a qualifying VSD can result in a 50 percent reduction in the base amount of a proposed civil penalty.
In reviewing the underlying conduct in a VSD, OFAC considers the totality of the circumstances surrounding the apparent violation, including the existence, nature, and adequacy of the subject’s compliance program at the time of the apparent violation and the corrective actions taken in response.
OFAC states that VSDs must include, or be followed within a reasonable period of time by, a sufficiently detailed report that provides a complete understanding of the circumstances of the apparent violation(s). When such a report is not included with an initial notification, OFAC will generally expect it within 180 days.
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