OFAC Launches New Voluntary Self‑Disclosure Portal
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced on February 6, 2026, the launch of its new online Voluntary Self‑Disclosure (VSD) Portal, representing a significant modernization of its sanctions enforcement processes.
Background and Purpose of the Portal
OFAC’s new VSD Portal is designed to streamline the submission of voluntary self‑disclosures by providing a centralized, secure online platform. According to OFAC, the system enhances efficiency, improves communication transparency, and creates a more user‑friendly experience for regulated parties.[1] According to OFAC, the Portal will serve as a modernized mechanism enabling faster acknowledgment, clearer communications, and a secure method of submission.
Key Functional Enhancements
- Faster Submission Acknowledgment - OFAC emphasizes that the portal enables quicker confirmation of VSD submissions, reducing uncertainty for reporting entities.
- Improved Communication Pathways - The platform establishes structured channels for communication, enabling clearer exchanges between disclosing parties and OFAC reviewers.
- Enhanced User Experience - The design of the Portal reflects OFAC’s focus on user experience, offering a more intuitive process for uploading narratives, supporting documents, and other required disclosures.
Regulatory Context
The launch of the VSD Portal aligns with broader regulatory trends within OFAC and related agencies. In 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule revising its voluntary self‑disclosure processes and articulating new penalty and aggravating factor considerations, influencing the overall enforcement landscape.[2] In addition, OFAC extended certain recordkeeping requirements from five to ten years, effective March 12, 2025, reinforcing the importance of robust compliance documentation.[3]
Strategic Importance of Voluntary Self‑Disclosures
Voluntary self‑disclosure remains one of the strongest mitigating factors in OFAC’s penalty determination framework. Entities that file qualifying VSDs may receive up to a 50% reduction in the base civil penalty when violations are substantiated.
To qualify as voluntary, disclosures must meet criteria outlined in OFAC’s Enforcement Guidelines, including truthful, complete, timely, and non‑misleading submissions, made before any government inquiry or investigation.
Practical Implications for Compliance Programs
Organizations subject to U.S. sanctions laws should take the following proactive steps to incorporate the new Portal into their compliance frameworks:
- Update internal reporting and escalation procedures to align with Portal submission requirements.
- Train compliance staff on identifying potential violations and preparing VSD materials.
- Review historical compliance gaps that may warrant disclosure under the new streamlined system.
- Strengthen recordkeeping processes to comply with OFAC’s extended ten‑year retention requirement.
Interagency Coordination Considerations
The Portal rollout also complements previous interagency efforts, such as the Tri‑Seal Compliance Note issued by DOJ, BIS, and OFAC, which clarifies expectations for voluntary disclosures across sanctions and export control regimes. Entities facing potential violations involving overlapping jurisdictions should carefully assess whether parallel disclosures to multiple agencies are warranted
Conclusion
The introduction of OFAC’s VSD Portal represents a significant step forward in modernizing the sanctions compliance ecosystem. By reducing administrative burdens and enhancing transparency, the Portal offers meaningful benefits to entities that choose to voluntarily disclose potential violations. Organizations should evaluate their compliance readiness and consider whether leveraging the new Portal aligns with their risk mitigation strategies.
For assistance evaluating potential disclosures, preparing VSD submissions, or updating sanctions compliance frameworks, our team is available to support your needs.
[1] Office of Foreign Assets Control (OFAC). Launch of Voluntary Self-Disclosure Portal, https://ofac.treasury.gov/recent-actions/20260206_33
[2] Bureau of Industry and Security (BIS). Voluntary Self-Disclosure, bis.gov/voluntary-self-disclosure
[3] Federal Register; Reporting, Procedures and Penalties Regulations, https://www.federalregister.gov/documents/2025/03/21/2025-04864/reporting-procedures-and-penalties-regulations