What should I do if I receive an OFAC subpoena?

Immediately issue a document hold, engage OFAC counsel, and do not discuss with anyone except counsel.

Can I voluntarily self-disclose during an investigation?

If the investigation reveals an unknown violation, voluntary disclosure through counsel can reduce penalties.

Typically 30 days. Extensions can be requested through counsel.

Yes. OFAC rewards cooperation with penalty mitigation. All cooperation through counsel.

Receiving an OFAC subpoena is serious. Your response quality directly affects enforcement outcomes.

Step 1: Preserve documents immediately

Issue a litigation hold. Preserve emails, transaction records, screening logs, compliance policies, training materials.

Step 2: Engage experienced OFAC counsel

Step 3: Conduct an internal investigation

Under counsel direction, investigate scope: which transactions, which counterparties, which controls failed.

Step 4: Consider voluntary self-disclosure

Scenario	Action
OFAC already knows	Cooperate fully
Unknown violation found	Consider voluntary self-disclosure
No violation found	Document and respond

Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.

What should I do if I receive an OFAC subpoena?: Immediately issue a document hold, engage OFAC counsel, and do not discuss with anyone except counsel.
Can I voluntarily self-disclose during an investigation?: If the investigation reveals an unknown violation, voluntary disclosure through counsel can reduce penalties.
How long do I have to respond?: Typically 30 days. Extensions can be requested through counsel.
Should I cooperate with OFAC?: Yes. OFAC rewards cooperation with penalty mitigation. All cooperation through counsel.