Voluntary Self-Disclosure Letter Template
A copy-paste voluntary self-disclosure letter template, structured for OFAC.
How to use
The letter
To: Office of Foreign Assets Control, Enforcement Division
Re: Voluntary Self-Disclosure of Apparent Violations — [Company]
Date: [Date]
Dear OFAC:
[Company] voluntarily discloses the following apparent violations of U.S. sanctions, in accordance with OFAC's Economic Sanctions Enforcement Guidelines.
1. Summary. [One paragraph: what happened, when, which sanctions program].
2. Parties involved. [Company, counterparties, and whether any is a blocked person].
3. Facts and timeline. [Chronology, transaction details, values, and the systems involved].
4. Root cause. [Why it happened — screening gap, agent path, human error].
5. Remediation. [Controls added since: screening, fail-closed behavior, audit logs].
6. Compliance program. [Your five-pillar program summary].
7. Contact. [Name, title, email, phone].
Sincerely,
[Name], [Title]
Why the structure
OFAC's guidelines reward complete, timely voluntary self-disclosure — it is a significant mitigating factor in penalty calculations. The structure mirrors what enforcement expects to see.