OFAC Investigations

An OFAC investigation is the formal process by which the Office of Foreign Assets Control examines a potential sanctions violation. Investigations can be triggered by voluntary self-disclosure, referral from another agency (FBI, FinCEN, OFAC itself), media reports, or blockchain analysis identifying sanctioned wallet activity.

The investigation process

1. OFAC opens an investigation and issues an administrative subpoena requesting documents and information. 2. The subject responds (through counsel). 3. OFAC determines whether a violation occurred and whether it was egregious or non-egregious. 4. The enforcement action may range from no action to a civil penalty to criminal referral.