US OFAC Sanctions Compliance Framework 501 App. A (VSD): Consider voluntary self-disclosure: it halves the base penalty, but only if self-initiated, complete and authorised

What does 501 App. A (VSD) require?

31 CFR Part 501 Appendix A, Sections I and V: a voluntary self-disclosure is a self-initiated notification to OFAC of an apparent violation before or when any government agency discovers it or a substantially similar one; it does not count if a third party must and does report a blocked or rejected transaction, if it is false, misleading or materially incomplete, prompted by an agency, or made by an individual without senior management authorisation; in the base penalty matrix a disclosed non-egregious case starts at one half of transaction value (capped) and a disclosed egregious case at one half of the statutory maximum.