Glossary

What is a Voluntary Self-Disclosure (VSD)?

OFAC enforcement mechanism where parties self-report violations to reduce penalties.

Definition

A VSD is a self-filed sanctions violation report to OFAC. OFAC strongly encourages it with penalty reductions.

Regulatory context

Timely VSD can reduce civil penalties by 50% compared to OFAC-discovered violations.

Who it affects

Any US person that discovers a sanctions violation must consider filing, including AI agent operators.

Relevance to AI agents

Automated screening with audit logs makes detection fast and documentation VSD-ready.

agentmail coverage

agentmail exports timestamped CSV: wallet, result, screen ID, latency - VSD evidence.

FAQ

1. How much does VSD reduce OFAC penalties?

A qualifying Voluntary Self-Disclosure roughly halves the base civil penalty compared with a violation that OFAC discovers on its own. Under OFAC's Enforcement Guidelines the base penalty amount is cut by up to 50%, which on a $330,944-per-transaction exposure is a very large incentive to detect and report quickly.

2. What evidence is needed for a VSD?

OFAC expects a detailed account of the apparent violation: what happened, the conduct that caused it, the parties and amounts involved, the remedial steps taken, and evidence of a strengthened compliance program. agentmail's timestamped screening logs supply much of this record, showing exactly what was checked and when.

3. How long does an OFAC investigation take?

OFAC enforcement matters commonly run from six months to two years, and complex cases can take longer. Because resolution is slow and document-intensive, retaining detailed, tamper-evident screening logs from the start is critical. agentmail's exportable CSV audit trail preserves that evidence across the entire investigation window.

Related glossary terms

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