Avoiding Penalties for a U.S. Individual's Unintentional OFAC Violation

Client Type and Situation:
A U.S. individual with accounts in banks that were later subjected to sanctions unknowingly continued transactions, unaware of the restrictions imposed on U.S. persons. Concerned about potential penalties, the client sought our help to self-disclose the violations to OFAC.

Approach and Research:
Our legal team conducted a comprehensive review of the client’s transactions, identifying the violations related to the continued use of the sanctioned accounts. We carefully examined the timeline, events, and relevant documentation to craft a detailed and accurate narrative of the circumstances.

Steps Undertaken:
We prepared the initial voluntary self-disclosure on the client’s behalf, organizing the explanation and supporting documents according to OFAC standards. After the initial disclosure was accepted, we submitted the final voluntary self-disclosure within the required timeframe, providing a full description of the violations and attaching the necessary evidence.

Outcome:
Three months after submission, OFAC closed the case without imposing any civil monetary penalty. The client was able to resolve the matter efficiently due to our firm's strategic handling of the self-disclosure process.