depending on the incident size and complexity

OFAC does, however, review the totality of the circumstances surrounding any apparent violation, including whether a matter was voluntarily self-disclosed to OFAC. Please review the Office of Compliance and Enforcement (“OCE”) Data Delivery Standards Guidance: Preferred Practices for Productions to OFAC, which details OFAC’s preferred technical standards for formatting electronic document productions submitted to OCE. Please submit all voluntary self-disclosures electronically to Unless the disclosure is an initial disclosure which will be supplemented with additional information, the submission should contain sufficient detail to afford OFAC a complete understanding of an apparent violation’s circumstances. Voluntary self-disclosure to OFAC is considered a mitigating factor by OFAC in enforcement actions, and pursuant to OFAC’s Enforcement Guidelines, will result in a reduction in the base amount of any proposed civil penalty.

OFAC encourages anyone who may have violated OFAC-administered regulations to disclose the apparent violation to OFAC voluntarily.

Because OFAC's programs are dynamic, it is very important to check OFAC's website on a regular basis to ensure that your sanctions lists are current and you have complete information regarding the latest restrictions affecting countries and parties with which you plan to do business. Entities that a person on the SDN List owns (defined as a direct or indirect ownership interest of 50% or more) are also blocked, regardless of whether that entity is separately named on the SDN List. persons are prohibited from dealing with SDNs wherever they are located and all SDN assets are blocked. A number of the named individuals and entities are known to move from country to country and may end up in locations where they would be least expected. In addition, OFAC maintains other sanctions lists that may have different prohibitions associated with them. The names are incorporated into OFAC’s list of Specially Designated Nationals and Blocked Persons ('SDN list') which includes approximately 6,400 names of companies and individuals who are connected with the sanctions targets. (Please see the “ Sanctions Programs and Country Information” page for information on specific programs.) It is important to note that in non-comprehensive programs, there may be broad prohibitions on dealings with countries, and also against specific named individuals and entities. Some programs are comprehensive in nature and block the government and include broad-based trade restrictions, while others target specific individuals and entities. economic sanctions and embargoes that target geographic regions and governments. OFAC itself was formally created in December 1950, following the entry of China into the Korean War, when President Truman declared a national emergency and blocked all Chinese and North Korean assets subject to U.S. After the United States formally entered World War II, the FFC played a leading role in economic warfare against the Axis powers by blocking enemy assets and prohibiting foreign trade and financial transactions. These controls were later extended to protect assets of other invaded countries. The FFC's initial purpose was to prevent Nazi use of the occupied countries' holdings of foreign exchange and securities and to prevent forced repatriation of funds belonging to nationals of those countries. The FFC program was administered by the Secretary of the Treasury throughout the war. OFAC is the successor to the Office of Foreign Funds Control (the 'FFC''), which was established at the advent of World War II following the German invasion of Norway in 1940. During the Civil War, Congress approved a law which prohibited transactions with the Confederacy, called for the forfeiture of goods involved in such transactions, and provided a licensing regime under rules and regulations administered by Treasury. Dating back prior to the War of 1812, Secretary of the Treasury Gallatin administered sanctions imposed against Great Britain for the harassment of American sailors. The Treasury Department has a long history of dealing with sanctions.

Depending on the incident size and complexity