OFAC's own guidelines cut penalty exposure substantially for qualifying voluntary self-disclosures — the rare enforcement regime that prices honesty explicitly. The decision is still not automatic, and botched disclosures forfeit the credit while keeping the exposure.
The credit belongs to disclosures OFAC learns from you first — before any third-party report, blocked-transaction filing by a bank, or investigation reaches the conduct. The clock races bank compliance departments, whose own reports are involuntary discovery from your side of the table. Qualifying also means complete: partial disclosures that unravel read worse than silence.
The bank's report covers what the bank saw — broader conduct it couldn't see may still be voluntarily disclosable. The scoping review answers what's left to win.
It means materially reduced exposure under published guidelines — cases still settle at real numbers when aggravating factors dominate. The math is case-specific and run before disclosing, not after.
Structured under privilege from the first interview, its protection is defensible; structured casually, it becomes the government's best exhibit. This is why the review precedes the decision.