Extract to table

Critically, the disclosure must not be triggered by an imminent threat of third-party disclosure — that is, it must represent a genuine, proactive decision to self-report rather than a reactive response to an inevitable revelation

The disclosure must also be comprehensive, including a thorough description of the apparent violation and all relevant facts

An initial VSD notification should be filed with OEE within a reasonable period after the potential violation is identified, and a full narrative report must follow within 180 days of the initial notification

Risks of Filing with OFAC We have also identified five principal risks associated with filing a VSD with OFAC, which must be weighed against the advantages described above

The public disclosure implications of an OFAC enforcement outcome must be carefully considered

The selective waiver protocol established in the July 1, 2022 memorandum must be carefully reviewed and, if necessary, supplemented to cover disclosures to OFAC