OFAC Launches New Online Voluntary Self-Disclosure Portal

Crowell & Moring Trade Blog

Published February 6th, 2026

Detected March 1st, 2026

Summary

The U.S. Department of Treasury’s Office of Foreign Assets Controls (OFAC) has launched a new online Voluntary Self-Disclosure (VSD) Portal to streamline reporting of potential sanctions violations. The portal aims to improve process visibility and communication for disclosing parties, and OFAC strongly encourages its use.

View original document View source feed page

What changed

OFAC has introduced a new online Voluntary Self-Disclosure (VSD) Portal, replacing previous ad hoc submission methods with a more secure and efficient channel for reporting potential sanctions violations. The portal is designed for completion in approximately 30 minutes and has specific file upload limitations (15 files, max 30MB each, common formats only). For extensive submissions, OFAC still directs users to its Production Submission Standards. This initiative is a reminder that qualifying VSDs are a significant mitigating factor in OFAC's penalty assessments, potentially leading to a 50% reduction in civil monetary penalties.

Regulated entities are strongly encouraged to begin using the new portal for all VSDs. Compliance officers should familiarize themselves with the portal's technical requirements, including file format and size restrictions, and the Production Submission Standards for large submissions. Prompt and proper self-disclosure remains a critical factor in mitigating potential enforcement actions and penalties, as outlined in OFAC's Economic Sanctions Enforcement Guidelines.

What to do next

Familiarize compliance teams with the new OFAC VSD Portal's features and requirements.
Update internal procedures to direct all future voluntary self-disclosures through the new online portal.
Review and adhere to the specified file upload limitations and formats for the portal, or the Production Submission Standards for extensive submissions.

Penalties

Qualifying VSD can result in a 50 percent reduction in the maximum possible civil monetary penalty.

Source document (simplified)

On February 6, 2026, the U.S. Department of Treasury’s Office of Foreign Assets Controls (OFAC) announced the launch of a new online Voluntary Self-Disclosure (VSD) Portal (the “New Portal”) intended to replace and reduce reliance on ad hoc submission methods with a more secure channel for reporting to OFAC potential sanctions violations. OFAC states that moving disclosures into the New Portal should improve process visibility for disclosing parties, including faster acknowledgment and clearer communication during OFAC’s review. Of note, “OFAC strongly encourages parties to begin submitting voluntary self-disclosures through” the New Portal.

From a submission mechanics standpoint, the New Portal’s form is designed to be completed in roughly 30 minutes and asks for core identifying information for the disclosing party and a primary correspondent (for example, if an entity or individual is represented by counsel), plus supporting documentation uploads. The New Portal limits uploads to 15 files, restricts file size to no larger than 30 megabytes (MB), and accepts only certain common formats (.PDF, .DOC, .DOCX, .XLS, .XLSX, .JPEG, .JPG or .PNG). Previously, there was a 150 MB maximum, with a maximum of 50 MB per email, before OFAC required submitting through a large file transfer system. As before, the New Portal requires optical character recognition (OCR) on all PDFs prior to submission.

For extensive or document-intensive submissions, OFAC requests that submitters continue to use OFAC’s Production Submission Standards, which cover package organization, sequential pagination, Excel-compatible spreadsheets, and transmission protocols, including secure transfers with ID.me authentication. Compliance with these standards may factor into OFAC’s evaluation of cooperation.

The New Portal is a reminder that OFAC’s current Economic Sanctions Enforcement Guidelines (the “Guidelines”) explicitly note that a qualifying VSD is treated as a mitigating factor in any penalty assessment. In addition, where OFAC determines a civil monetary penalty is warranted, a qualifying VSD can result in a 50 percent reduction in the maximum possible penalty (with the precise calculation mechanics depending on whether OFAC treats the case as egregious or non-egregious), provided the VSD meets the criteria in the Guidelines. As we have previously noted, organizations that promptly report potential violations to OFAC may receive reduced penalties or even avoid enforcement altogether.

Crowell & Moring LLP regularly advises U.S. and foreign companies on VSDs to OFAC and related investigations. Please contact the authors regarding questions about VSDs or the New Portal.

Subscribe to this blog by email

On Demand Webinars

Supply Chain Mapping in the Era of National Security: Strategies for Trade Compliance, Tariff Mitigation, and Human Rights Risk

Zeus Logics: Navigating Transshipment Tariffs, UFLPA Enforcement, & Supply Chain Exposure

Passport to U.S. Customs Compliance

Navigating Agency and Congressional Investigations for Federal Funding Recipients Webinar

Blog Authors

Stay Connected

Subscribe to this blog

First Name Last Name Company

Topics

Recent Updates

Crowell & Moring Blogs

About this blog

Crowell & Moring is a full-service international law firm that represents major businesses – both public and private – in complex high-stakes litigation, enforcement, regulatory and administrative, transactional matters, and government and internal investigations. Our Trade Law Blog features legal insight and thought-leadership affecting the industries and business reliant and affected by international trade.