OFAC Voluntary Self-Disclosure video
Every past shipment and payment screened against the list of its own day, the base penalty shown with and without disclosure, and the notice to OFAC and BIS drafted with every item cited. 1:19
What the film shows
Looks back over historic transactions for sanctions breaches and drafts the disclosure
Agents screen every historic record against the sanctions list versions in force on its date, trace owners under the 50 Percent Rule, classify the apparent violations and compute the base penalty on OFAC's two-by-two matrix with and without disclosure. They draft the notices to OFAC and BIS with every item cited; the partner decides and signs, and the client's General Counsel authorizes filing.
Transcript
- OFAC Voluntary Self-Disclosure finds sanctions breaches for counsel and drafts the disclosure.
- Disclosure halves OFAC's base penalty, and lookbacks reach ten years.
- 212,000 shipments and payments, screened against each day's lists.
- The distributor's owner: a blocked Russian trader with fifty-one percent.
- Seventeen apparent violations, 3.4 million dollars, each one cited.
- On OFAC's matrix, each violation is a dot by value.
- Isadora toggles disclosure: the base penalty falls from five million to 1.7 million.
- She decides to disclose to OFAC and BIS, and signs.
- The cited notice is drafted; the client authorizes filing.
- A complete lookback in four days, and half the base penalty.
- Built on Botminds: agents, data, screens and governance on one platform.
The narration as written for the film. Captions are on the player.