Recommendations to OFAC Guidelines on Self-Disclosure
The Clearing House Association urged OFAC to reinstitute the Economic Sanctions Enforcement Procedures for Banking Institutions that were published as an interim final rule in 2006, rather than implement the new Enforcement Guidelines. TCH also strongly recommended that OFAC revise the definition of voluntary self-disclosure by removing language indicating that disclosure is not voluntary if a third person has already disclosed the violation.
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