Voluntary Self-Disclosure Letter Template

A copy-paste voluntary self-disclosure letter template, structured for OFAC.

How to use

How to use: adapt the bracketed fields. Consult counsel before filing — this template is a starting structure, not legal advice.

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.

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