Voluntary Self-Disclosure by a U.S. Individual resulting in closure of the case without OFAC Penalties

Client Type and Situation:
A U.S. individual unknowingly continued to use accounts at banks that were later subject to sanctions, not realizing that as a U.S. person, they were no longer permitted to transact with these institutions. After discovering the issue, the client sought our firm’s assistance to voluntarily disclose the violations to OFAC.

Approach and Research:
We conducted a thorough review of the client’s financial activities, identifying the transactions that occurred in violation of sanctions. Our legal team carefully examined the relevant timelines, documentation, and background to fully understand the context of the violations.

Steps Undertaken:
We promptly prepared and submitted an initial voluntary self-disclosure on the client’s behalf, providing a general account of the circumstances. After the initial submission was accepted, we worked within the required timeframe to compile and submit the final voluntary disclosure, including a complete explanation of the violations and supporting documentation, which was meticulously organized to meet OFAC’s submission requirements.

Outcome:
After four months of review, OFAC closed the case without issuing any civil monetary penalties. Our client was able to successfully navigate the process and avoid financial penalties thanks to our effective handling of the disclosure.