OFAC voluntary self-disclosure resolved with cautionary disposition
Situation:
The U.S. branch of a major global financial institution identified apparent issues involving transactions potentially implicating the Iran sanctions program. The institution required an internal review and regulatory assessment to evaluate exposure, preserve credibility with regulators, and determine whether a voluntary self-disclosure to OFAC was appropriate.
Stakes:
The matter involved potential OFAC enforcement exposure tied to sanctions compliance controls, transaction monitoring, and cross-border banking activity. The institution faced regulatory, operational, and reputational risk, including the possibility of civil penalties, expanded inquiries, and increased scrutiny from regulators and correspondent banking partners. The disclosure required a carefully documented presentation of the facts, compliance environment, remediation efforts, and mitigating considerations.
Result:
Ferrari & Associates represented the institution in preparing and submitting a voluntary self-disclosure to OFAC concerning apparent violations of the Iran sanctions program. Following review of the submission and related materials, OFAC issued a cautionary letter and took no further enforcement action against the bank.
