OFAC LAUNCHES VOLUNTARY SELF-DISCLOSURE PORTAL
March 6, 2026
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On February 6, 2026, the Treasury Department’s Office of Foreign Assets Control announced a new online Voluntary Self-Disclosure Portal (available here) where regulated entities can voluntarily self-disclose apparent violations of OFAC-administered sanctions. As the federal agency responsible for administering and enforcing U.S. economic and trade sanctions, OFAC often investigates airlines, air charter operators, travel agents, and service providers to mitigate illegal trafficking networks which often exploit transportation services to circumvent U.S. sanctions. OFAC regulations are enforced on a strict liability basis which means that those enforcing U.S. economic and trade sanctions do not need to prove fault or intent to take enforcement action and issue a significant civil penalty. To encourage compliance among regulated entities, OFAC advised that voluntary self-disclosures will be a significant mitigating factor when the agency determines whether to take enforcement action and could even result in a fifty (50) percent reduction in any penalty assessed against violators. Foreign air carriers subject to OFAC-administered sanctions should contact legal counsel to strengthen internal controls so that they can promptly investigate and disclose potential violations as needed.
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