On February 6, 2026, the U.S. Department of Treasury’s Office of Foreign Assets Controls (OFAC) announced the launch of a new online Voluntary Self-Disclosure (VSD) Portal (the “New Portal”) intended to replace and reduce reliance on ad hoc submission methods with a more secure channel for reporting to OFAC potential sanctions violations. OFAC states that moving disclosures into the New Portal should improve process visibility for disclosing parties, including faster acknowledgment and clearer communication during OFAC’s review. Of note, “OFAC strongly encourages parties to begin submitting voluntary self-disclosures through” the New Portal.

From a submission mechanics standpoint, the New Portal’s form is designed to be completed in roughly 30 minutes and asks for core identifying information for the disclosing party and a primary correspondent (for example, if an entity or individual is represented by counsel), plus supporting documentation uploads.  The New Portal limits uploads to 15 files, restricts file size to no larger than 30 megabytes (MB), and accepts only certain common formats (.PDF, .DOC, .DOCX, .XLS, .XLSX, .JPEG, .JPG or .PNG). Previously, there was a 150 MB maximum, with a maximum of 50 MB per email, before OFAC required submitting through a large file transfer system. As before, the New Portal requires optical character recognition (OCR) on all PDFs prior to submission.

For extensive or document-intensive submissions, OFAC requests that submitters continue to use OFAC’s Production Submission Standards, which cover package organization, sequential pagination, Excel-compatible spreadsheets, and transmission protocols, including secure transfers with ID.me authentication. Compliance with these standards may factor into OFAC’s evaluation of cooperation.

The New Portal is a reminder that OFAC’s current Economic Sanctions Enforcement Guidelines (the “Guidelines”) explicitly note that a qualifying VSD is treated as a mitigating factor in any penalty assessment. In addition, where OFAC determines a civil monetary penalty is warranted, a qualifying VSD can result in a 50 percent reduction in the maximum possible penalty (with the precise calculation mechanics depending on whether OFAC treats the case as egregious or non-egregious), provided the VSD meets the criteria in the Guidelines. As we have previously noted, organizations that promptly report potential violations to OFAC may receive reduced penalties or even avoid enforcement altogether.

Crowell & Moring LLP regularly advises U.S. and foreign companies on VSDs to OFAC and related investigations. Please contact the authors regarding questions about VSDs or the New Portal.

Tags: OFAC, Sanctions
Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Anand Sithian Anand Sithian

For high-stakes internal and government investigations and complex regulatory and compliance matters, companies and individuals look to Anand to provide strategic advice and counseling, particularly on issues relating to the Bank Secrecy Act and Anti-Money Laundering (“BSA/AML”), economic sanctions, and digital assets. Anand

…

For high-stakes internal and government investigations and complex regulatory and compliance matters, companies and individuals look to Anand to provide strategic advice and counseling, particularly on issues relating to the Bank Secrecy Act and Anti-Money Laundering (“BSA/AML”), economic sanctions, and digital assets. Anand is resident in the firm’s New York office and a member of the firm’s International Trade, White Collar and Regulatory Enforcement, and Financial Services groups.

A former federal prosecutor, Anand leverages his government experience to guide clients through complex white-collar matters, including grand jury and regulatory investigations, enforcement proceedings, and internal investigations. Anand has deep experience in parallel criminal and civil investigations and proceedings, and often represents clients in defending against civil lawsuits related to government investigations.

Representing some of the world’s largest banks and technology companies, Anand has addressed a wide range of issues, including economic sanctions, BSA/AML; economic sanctions and national security; payments and cryptocurrency; securities laws; and cybersecurity enforcement. In the regulatory space, Anand prides himself on providing commercial and actionable advice, including in the developing areas of digital assets, FinTech, and payments.

Read more about Anand Sithian
Show more Show less
Photo of Jeremy Iloulian Jeremy Iloulian

Recognized as a “Rising Star” in International Trade by Super Lawyers, Jeremy Iloulian advises clients globally on complex cross-border regulatory, compliance, investigative, and transactional matters and policy developments that touch U.S. national security, international trade, and foreign investment, including those relating to

…

Recognized as a “Rising Star” in International Trade by Super Lawyers, Jeremy Iloulian advises clients globally on complex cross-border regulatory, compliance, investigative, and transactional matters and policy developments that touch U.S. national security, international trade, and foreign investment, including those relating to U.S. export controls (EAR and ITAR), economic sanctions, anti-boycott laws, the Committee on Foreign Investment in the United States (CFIUS), and various national security controls on fundamental research and supply chains.

Jeremy has extensive experience counseling U.S. and non-U.S. clients, including public and private companies, private equity sponsors, and nonprofits spanning a multitude of industries, including aerospace and defense, energy, entertainment, fashion, food and beverage, health care, infrastructure, technology, telecommunications, and transportation. He provides strategic guidance on managing risks for dealings in high-risk jurisdictions such as China, Russia, Venezuela, and the Middle East, among other countries and regions. He regularly advocates on behalf of such clients before the U.S. Bureau of Industry and Security (BIS), Directorate of Defense Trade Controls (DDTC), Office of Foreign Assets Control (OFAC), Bureau of Economic Affairs (BEA), Census Bureau, Department of Energy, and Nuclear Regulatory Commission (NRC).

Additionally, Jeremy has previously counseled on, presented on, and published research related to international environmental law, specifically the United Nations Convention on the Law of the Sea (UNCLOS) and Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES).

Prior to and during law school, Jeremy interned at multiple government agencies, including the United Nations, the U.S. State Department, and the Iraqi Embassy in Washington, D.C.

Read more about Jeremy Iloulian
Show more Show less
Dmitry Bergoltsev

Dmitry Bergoltsev is a Senior International Trade Specialist I in Crowell & Moring’s Washington, D.C., office. With professional fluency in Russian and Mandarin, Dmitry bridges language and cultural barriers, offering valuable insights for clients navigating complex global trade and regulatory matters. He works…

Dmitry Bergoltsev is a Senior International Trade Specialist I in Crowell & Moring’s Washington, D.C., office. With professional fluency in Russian and Mandarin, Dmitry bridges language and cultural barriers, offering valuable insights for clients navigating complex global trade and regulatory matters. He works closely with attorneys to develop practical solutions for clients facing challenges before the Office of Foreign Assets Control (OFAC), U.S. Customs and Border Protection (CBP), the Bureau of Industry and Security (BIS), and other federal agencies. Dmitry’s key areas of focus include advising clients on sanctions and export controls compliance, U.S. import and export regulations, and supply chain due diligence, with particular attention to the geopolitical and regulatory risks our clients face when operating across global markets.

Read more about Dmitry Bergoltsev
Show more Show less
Related Posts
OFAC Sanctions Rwanda’s Military
March 2, 2026
Altomare SA and Kallista Removed from OFAC’s SDN List
January 26, 2026
BIS Issues “Affiliates Rule” to Dramatically Expand Applicability of Entity and Military End-User Lists
October 7, 2025