Is there a deadline for voluntary self-disclosure?

No fixed deadline, but disclosing ASAP maximizes penalty mitigation. A full report should follow within 180 days of initial notification.

What makes a disclosure 'voluntary'?

OFAC must not already know about the violation, no inquiry or subpoena must be pending, and the disclosure must be complete and truthful.

Should I disclose through counsel?

Yes. Always use experienced OFAC counsel for voluntary self-disclosure. Counsel manages privilege and strategy.

OFAC voluntary self-disclosure timeline

Voluntary self-disclosure to OFAC has no fixed deadline, but speed matters. Disclosing before OFAC discovers the violation independently maximizes penalty mitigation.

The disclosure timeline

What makes disclosure 'voluntary'

To qualify as voluntary: (1) OFAC must not already know about the violation, (2) the disclosure must be made before any OFAC inquiry, subpoena, or investigation, (3) the disclosure must be complete and truthful.

Stage	Timeline	Action
Discovery	Day 0	Identify potential violation
Initial notification	ASAP (days, not weeks)	Notify OFAC of apparent violation
Full report	Within 180 days	Submit detailed report with findings
Remediation	Ongoing	Implement corrective measures

Penalty impact: Voluntary self-disclosure creates a presumption of mitigation. Combined with cooperation and remediation, penalties can be reduced by 50% or more.

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Frequently Asked Questions

Is there a deadline for voluntary self-disclosure?: No fixed deadline, but disclosing ASAP maximizes penalty mitigation. A full report should follow within 180 days of initial notification.
What makes a disclosure 'voluntary'?: OFAC must not already know about the violation, no inquiry or subpoena must be pending, and the disclosure must be complete and truthful.
How much does voluntary disclosure reduce penalties?: It creates a presumption of mitigation. Combined with cooperation and remediation, penalties can be reduced by 50% or more.
Should I disclose through counsel?: Yes. Always use experienced OFAC counsel for voluntary self-disclosure. Counsel manages privilege and strategy.