OFAC Issues Guidance on Submitting Info During Investigations, Disclosures

The Office of Foreign Assets Control this month released new guidance to outline how people and companies should submit information, documents and “other materials” to the agency during a sanctions breach investigation, for voluntary disclosure, in response to an OFAC subpoena, and more. The guidance updates the agency’s “former data delivery standards,” OFAC said, and “provides technical and general guidance to persons submitting material to OFAC,” especially for submissions “that may entail voluminous documentation (e.g., more than 100 pages).” The document includes guidance for “organizing document productions,” includes “general conventions for submitting electronic documents,” and provides guidance on submitting data under and over 150 megabytes in total size.