Insights

On February 6, 2026, the Department of the Treasury Office of Foreign Assets Control (OFAC) announced a new voluntary self-disclosure (VSD) portal focused on providing a streamlined, secured method to submit VSDs of potential violations of OFAC sanctions.

OFAC Sanctions and VSDs

OFAC administers and enforces economic sanctions on individuals, organizations, and foreign jurisdictions and regimes that are involved in harmful activity and threaten the economy, foreign policy, and national security of the United States. Economic sanctions generally involve the blocking of property of sanctioned persons, prohibitions against certain financial transactions, and sectoral prohibitions in a sanctioned country’s economy. To aid with compliance, OFAC provides information about sanctioned persons on its restricted parties lists, including the Specially Designated Nationals and Blocked Persons List (SDN List) and the Non-SDN List.

OFAC can bring criminal and civil penalties against those who violate sanctions regulations. In 2025, OFAC ramped up enforcement across multiple sectors, even levying a $215,988,868 fine against GVA Capital Ltd. for egregious violations and a failure to self-disclose. As indicated in this case, parties can significantly mitigate penalties for a potential violation by submitting a VSD to OFAC. In fact, according to the OFAC Economic Sanctions Enforcement Guidelines, a VSD to OFAC can lead to a 50% decrease in the potential base penalty. While a party should determine whether it is advantageous to self-disclose on a case-by-case basis, parties that choose not to self-disclose risk higher penalties in a potential enforcement action. For more information and a comprehensive guide on VSDs to OFAC and other agencies, see the Torres Trade Law Voluntary Self-Disclosure Handbook.

OFAC’s New VSD Portal

OFAC’s new portal allows companies to submit VSDs online. OFAC looks to increase transparency and efficiency with the portal, aiming for a smoother user experience, faster acknowledgement of submissions, and clearer communication during the review process. OFAC strongly encourages relevant parties to submit VSDs through the new online portal.

OFAC’s transition to an online system for VSDs may make self-disclose a faster and smoother path for parties looking to submit self-disclosures of OFAC sanctions. If you have any questions or concerns about OFAC sanctions and VSD submission, please contact the professionals at Torres Trade Law.