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OFAC Voluntary Self-Disclosure

OFAC voluntary self-disclosure that screens years of shipments and payments against the sanctions list of each record’s own date, prices the base penalty both ways and drafts the notice.

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Follow one lookback through to the signed notice ↓
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The problem

Years of shipments to retest, and a disclosure call due before the figure

A client learns that a distributor may belong to a sanctioned trader. Counsel must find each shipment and payment that touched it, test each against the list as it stood that day, and trace each counterparty’s owners through foreign registries. With a consultancy, that takes weeks.

The disclosure clock runs all the while. Credit is lost if the regulator hears first, from a bank’s blocking report, a whistleblower or another agency. Partners know disclosure halves the base penalty, yet must advise before anyone knows what half comes to here, and the longer limitation period pulls more years into each lookback.

Built forSanctions partnersTrade compliance counselCompliance analystsIn-house counsel

The Problem Today

Disclosure halves the base penalty only when it reaches the regulator first, and lookbacks now reach back ten years.

10 years
limitation period for sanctions breaches since 2024, up from 5 published
$297.5M
sanctions penalties, 10 enforcement actions, so far in 2026 published

Worked manually today

  • Records
  • List dates
  • Owners
  • Notices
  • A forensic project per matterAssociates and consultants rebuild the lookback by hand
  • Advice before the arithmeticThe partner weighs disclosure on a rule of thumb

The Solution

  1. Each record, its day’s listShipments and payments retested against the list version of their own date
  2. Blocked stakes added upA company on no list is still blocked when listed owners hold half
  3. The penalty priced both waysThe guidelines’ matrix applied to the transactions actually found
  4. Partner signs, client authorizesNotices to the sanctions and export regulators, each item cited

Built-in controls

  • Only the partner decides whether to disclose
  • Agents file and send nothing
  • Each result keeps the list version it was tested on

What You Get

The partner decides on disclosure knowing its dollar value, and files while the credit is still there to earn.

4 days
for a five-year lookback, down from 6–8 weeks our estimate
½
the base penalty when the disclosure comes first published
  • A schedule the regulator can followEach violation tied to its invoice, shipment and payment
  • Earlier years checked tooThe longer reach tested against those years’ own lists
  • Duties kept apartAnalyst, associate, partner and client each sign their own part
From lookback to signature

OFAC voluntary self-disclosure in nine features, each record on its own date

From the first rescreen of old shipments to the client’s go-ahead to file, each feature with the role that leans on it.

  1. 01Lookback

    A lookback that tests each record against the list in force on its date

    How it works

    • 212,000 shipments and payments screened against 1,293 stored list versions in 3 h 12 min
    • Each result keeps the list version it was tested against
    • 1,214 potential matches narrow to 51 alerts for people and 17 apparent violations
    • An order that passed at entry matches at 0.98 on its shipping date

    Trade compliance analystStops retesting old shipments against today’s list, which says nothing about what was lawful the day the goods left.

  2. 02Alerts cleared by people

    Alerts cleared by a person, with the reason written on each one

    How it works

    • Matches above 0.92 and each ownership hit go to a person
    • The agent clears lower scores only when it writes down why
    • The analyst reread 120 of its 1,163 clearances and agreed with all 120
    • Of 51 alerts, people cleared 34 and sent 17 on to the associate

    Trade compliance analystCan defend each cleared name a year from now, because the reason sits on the alert itself.

  3. 03Parties and ownership

    Blocked owners added together, so a distributor on no list shows as blocked

    How it works

    • Owners of 4,318 counterparties traced through four layers, each stake cited to its registry
    • A 51% stake held by a listed trader makes the distributor blocked property
    • The forwarder’s blocked owners hold 24%, so it stays on watch
    • A missing registry record goes to the analyst; 41 were cleared with documents

    Sanctions associateSees why twelve shipments to a company that appears on no list are still apparent violations, with the shareholder register to show for it.

  4. 04Apparent violations

    A schedule of apparent violations, each value tied to its records

    How it works

    • Each row carries the ship date, order, counterparty, goods and value
    • Invoice and payment links open the passage each figure was read from
    • Filters split 5 direct shipments, 12 through the distributor, 2 possibly egregious and 3 export matters
    • Confirm a row, set it aside with a stated reason, or flag it for the partner

    Sanctions associateConfirms each violation against its invoice, bill of lading and payment before a sentence of the notice is written.

  5. 05V-02 and its records

    Possibly egregious shipments flagged, with the email behind each flag

    How it works

    • The classifier reads the internal mail around each shipment
    • V-02 left after a sales manager urged the desk to ship the backlog before the list changed
    • It proposes not egregious for the case, with that email disclosed in full
    • Only the partner rules on egregiousness

    Sanctions partnerJudges egregiousness on the evidence itself, with the invoice, bill of lading and payment open beside the email that raised the question.

  6. 06Penalty calculator

    The base penalty worked out for each violation, cell by cell

    How it works

    • Schedule amount, half the value, statutory maximum and half the maximum, per shipment
    • Not egregious comes to $4,999,300 undisclosed and $1,706,320 disclosed
    • With V-02 and V-03 egregious, $5,406,400 and $1,996,945
    • Credit for a first violation or cooperation is shown as an estimate

    Sanctions associateHands the partner the arithmetic behind each cell, so the figure holds up when the client’s general counsel checks it.

  7. 07Penalty matrix

    One switch shows what disclosure is worth before anyone decides

    How it works

    • The guidelines’ two-by-two, each violation a dot sized by its value
    • Switching to voluntarily disclosed moves all 17 dots to the lower row
    • The range falls from $5.00M–$5.41M to $1.71M–$2.00M
    • That is $3.29M–$3.41M off the base penalty, 63–66%

    Sanctions partnerWalks into the client meeting with the dollar value of disclosing, not a rule of thumb about halving.

  8. 08Decision on disclosure

    The decision to disclose, signed with its reason on the record

    How it works

    • Four choices, from disclosing to both regulators to waiting for more facts
    • A reason drafted from the schedule and the penalty range, open to rewrite
    • Signed by the partner typing a full name; no other role can sign
    • A separate choice on how to treat V-02 and V-03

    Sanctions partnerLeaves a reason a successor partner or the regulator can read later, written when the decision was made.

  9. 09Initial notification

    An initial notification with each statement cited, signed for the client

    How it works

    • How it was found, the lookback, the violations, cause and remediation
    • 23 citations, each linking a statement to its record, checked by the associate
    • The four tests of a voluntary self-disclosure tracked beside the draft
    • The associate files only after the client authorizes; agents file nothing

    Client general counselReads a notice the partner has already signed, with the schedule behind it, before committing the company to file.

Disclosing takes $3.29M to $3.41M off the base penalty for these 17

The base penalty from the transactions found, on the guidelines’ two-by-two. The regulator sets any penalty.

For the 17 foundNot disclosedVoluntarily disclosed
All 17 not egregious$4,999,300$1,706,320
V-02 and V-03 egregious$5,406,400$1,996,945
Range$5.00M–$5.41M$1.71M–$2.00M

A distributor’s 51% owner, a pre-listing backlog and an email about the list

Four findings from one lookback, each in the schedule with its records.

A buyer on no list, blocked through its owner

Twelve shipments worth $2,146,590 went to a distributor on no list. Its register shows a listed trader holding 51%, so each is an apparent violation.

A backlog ordered before the listing

Five orders entered before the trader was listed shipped after it. Screened at entry they passed; against the list of the shipping date, the first matches at 0.98.

An email that may make two egregious

A regional sales manager told the order desk to ship the backlog before anyone updated the list. V-02 and V-03, $312,800 and $268,450, left after it.

A forwarder that stays under half

The forwarder that carried all 17 is 24% owned by the listed trader and 20% by an unlisted holder. Only blocked stakes count, so it stays on watch.

Around the matter

The sanctions lookback file the notice rests on

Opened around the schedule by the analyst, the associate and the client.

Each party and its bankThe parties in the disclosure and their banks: listing status, blocked owners, shipments or payments, the evidence and who checked it.
The register behind the 51%Each ownership stake opens the registry extract it came from: here the distributor’s shareholder register, with 510 shares held by the listed trader.
The parallel export noticeThree shipments of export-controlled bellows-seal valves, $597,350, go to the export regulator as well. Its full narrative follows within 180 days.
Two root causes, seven fixesOrders screened only at entry, and nobody checking who owned the distributor. Seven steps with owner, due date and status, two done.
Who did what, and on whatScreens, clearances, confirmations, the decision and the signatures, agents and people in one trail, each with its reference.
Duties kept apartFive roles and what each may do. The analyst who reviews an alert does not confirm the violation, and only the client authorizes filing.

Analyst, associate, partner and client each sign a different part

Agents prepare the matter. People clear, confirm, decide and authorize.

Trade compliance analyst
Sees
The alerts above the agent’s line, and a share of the agent’s own clearances
Signs
Clears or escalates each alert, with a reason
Sanctions associate
Sees
The schedule, each row with its records and source passages
Signs
Confirms each apparent violation and checks each citation
Sanctions partner
Sees
The matrix, the penalty workings, the egregiousness flags and both drafts
Signs
The decision to disclose, and both initial notifications
Client general counsel
Sees
The signed notices, the schedule and the remediation plan
Signs
Authorizes filing, and commits the company to each fix
Prepared, never decided

Six agents run the lookback; only the partner decides to disclose

What each agent does, and the line it is held to.

Lookback screener

Screens each shipment and payment against the list versions in force on its date, and clears false matches with a written reason.

  • Never screens a past record against today’s list
  • Never clears a match above 0.92 without a person
Ownership tracer

Traces the owners of each counterparty through four layers and adds blocked stakes together, citing the registry.

  • Never treats a missing registry record as clear
Violation classifier

Turns confirmed hits into apparent violations with rule, date, value, limitation and export overlap, and proposes a view on egregiousness.

  • Never decides egregiousness
Penalty calculator

Applies the guidelines’ base-penalty matrix to the transactions found, with and without disclosure.

  • Never presents an estimate as the regulator’s penalty
Disclosure drafter

Drafts the initial notifications and narratives to both regulators, each item cited to a record.

  • Files and sends nothing; a person files
Remediation planner

Finds the root causes and proposes fixes, each with an owner and a date.

  • Never commits the client to a step without its general counsel

Before a partner advises on OFAC voluntary self-disclosure

What is OFAC voluntary self-disclosure?

OFAC voluntary self-disclosure is a company’s own notice to the sanctions regulator of an apparent violation, made before the regulator learns of it another way and followed by a detailed report. This solution runs the lookback behind it, prices the base penalty with and without disclosure, and drafts the notice for a partner to sign.

Why test each record against the list of its own date?

A party listed last month says nothing about a shipment made before its listing. Each record is tested against the stored list version of its own date, and that version is kept with the result.

How does it treat a company that appears on no list?

The ownership tracer adds together the stakes held by blocked owners. When they reach half, the company is treated as blocked even though no list names it. Each stake is cited to its registry extract, and a company with no registry record goes to the analyst.

Is the penalty on the matrix the regulator’s penalty?

No. It is the base penalty the enforcement guidelines set for the transactions found, the starting point before the general factors. Credit for a first violation or for cooperation is shown as an estimate, and the regulator sets any penalty.

What happens when the goods were also export-controlled?

Those shipments are flagged on the schedule, and a parallel notice to the export regulator is drafted from the same records and citations ready for the partner’s signature.

Who can file the disclosure?

Agents file and send nothing. The partner signs, the client’s general counsel authorizes filing for the company, and the associate files, each step in the audit trail.

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Put a dollar figure on disclosing
while the credit is still there.

We’ll screen a past matter against the lists of its own dates and show your partners the matrix it produces.

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