On February 6, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) launched a new online portal allowing companies to submit voluntary self-disclosures of potential US sanctions violations through a web-based form. The development reflects OFAC’s continued encouragement that companies self-disclose misconduct. The portal also serves to highlight OFAC’s focus on improving the efficiency of its own enforcement and compliance framework.
While the new platform does not change the substantive requirements for self-reporting, it is designed to streamline the submission process, improve document handling, and enhance OFAC’s ability to track and process disclosures.
Background
Under OFAC’s enforcement guidelines, companies that proactively and voluntarily disclose apparent violations before OFAC discovers them may receive a significant reduction in any subsequent penalty.[1]
Historically, companies have submitted voluntary self-disclosures by email, often attaching large volumes of sensitive supporting documentation, as required by OFAC. The size and sensitivity of these materials have created logistical challenges for secure transmission. Although OFAC can establish secure file-sharing links on a case-by-case basis, the new portal is expected to mitigate these challenges, offering a more secure and streamlined process for companies engaging in voluntary self-disclosure.
Accordingly, the portal reflects a procedural change in how disclosures are submitted — not a change in the substance of what companies are required to disclose. In addition to the new portal, OFAC will continue to accept self-disclosure reports via email.
Key Features of the New Online Portal
The portal is designed to facilitate a two-step disclosure process: (1) an initial submission, which notifies OFAC of a potential violation and triggers the start of the disclosure timeline; and (2) a final submission, which provides a detailed report following completion of the company’s internal investigation. The launch of the portal does not change the disclosure timeline. OFAC still expects companies using the portal to submit a detailed follow-up report within 180 days of the initial notification.
OFAC has previously published guidance regarding production submission standards and the documentation it expects to receive in connection with voluntary disclosures. The portal is designed to better align submissions with those expectations while simplifying document handling for both companies and OFAC. As noted above, the portal allows users to upload multiple supporting documents directly to OFAC securely, and efficiently. This functionality may reduce the need to transmit large files or sensitive transactional materials via email, a process that has historically presented logistical and confidentiality concerns.
What Has Not Changed
Importantly, the portal does not alter:
- What constitutes a voluntary self-disclosure;
- The requirement that disclosure occur before OFAC independently discovers the violation; or
- The requirement to provide a comprehensive account of the relevant facts and circumstances.[2]
Companies must still ensure that their disclosures are complete, accurate, and supported by sufficient documentation to allow OFAC to understand the nature, root cause, and scope of the apparent violation.
Conclusion
OFAC’s new voluntary self-disclosure portal represents an administrative modernization rather than a substantive shift in enforcement policy. By streamlining intake and facilitating structured submissions, the platform may encourage timely reporting and improve coordination between companies and OFAC.
Companies operating, or transacting with others, in high-risk jurisdictions, or engaging in complex cross-border transactions should consider whether OFAC’s new tool could be useful in their own sanctions compliance and internal investigation protocols.
If you have questions about OFAC’s voluntary self-disclosure process or would like further guidance on how to take advantage of this new resource, contact Bracewell’s government enforcement and investigations team.
[1] For example, Córdoba Music Group LLC, a California-based manufacturer of musical instruments, substantially reduced its exposure by voluntarily self-disclosing its violations of US sanctions on Iran to OFAC. The company ultimately agreed to pay $41,591 to settle its civil liability. By contrast, the statutory maximum civil monetary penalty applicable to the apparent violations was $3,313,224 — illustrating the significant mitigation that can result from timely voluntary self-reporting and cooperation. See Córdoba Music Group LLC Settles with OFAC for $41,591 Related to Apparent Violations of the Iranian Transactions and Sanctions Regulations, Office of Foreign Assets Control, Enforcement Release (Dec. 18, 2024).
[2] Further information on the specific information OFAC requires companies self-disclosing violations to provide can be found here: https://ofac.treasury.gov/media/932996/download?inline.
