Official Reporting Channels

Anyone under U.S. jurisdiction holding property of a designated party must block it and report to OFAC within 10 business days. Rejected transactions follow the same deadline. There is also an annual report of property that remains blocked, due by September 30. Filing is done through the official OFAC Reporting System (ORS); access registration is requested by e-mail at OFACReport@treasury.gov.

For compliance questions, such as a possible name match in screening, the official channel is OFAC’s Compliance Hotline. If an internal review concludes that the company itself may have taken part in a prohibited transaction, voluntary disclosure is made through the Self Disclosure Portal and is a mitigating factor, reducing the base amount of any civil penalty. This decision should be made with specialized legal counsel.

Financial institutions subject to U.S. regulation file the Suspicious Activity Report (SAR) through the BSA E-Filing system. For suspected terrorism-related activity, FinCEN maintains a 24-hour urgent hotline, which speeds up delivery of the information to the authorities and does not replace the SAR. Anyone with information about sanctions violations may use the whistleblower program, with awards available when penalties exceed US$ 1 million.

Urgent hotline (terrorism): 1-866-556-3974 — 24/7

Any person, company or institution, inside or outside the United States, may report information about terrorist activity or a U.S. federal crime directly to the FBI, through the official form or by phone. Tips may be submitted anonymously.

Phone: 1-800-CALL-FBI (1-800-225-5324)

Companies in the sectors listed in art. 9 of Law No. 9,613/1998 — financial institutions, payment services, real estate, high-value goods, factoring and accounting, among others — have a legal duty to report transactions suspected of money laundering or terrorist financing to COAF, exclusively through the SISCOAF portal. Good-faith reporting does not create civil or administrative liability (art. 11). Access requires prior enrollment and Gov.br authentication with two-step verification. Deadlines vary by sector regulator: report after concluding the internal review and confirm the applicable deadline in your regulator’s rules.

Evidence of ties to a designated criminal faction often constitutes evidence of a crime in Brazil, such as participation in a criminal organization, money laundering or the offenses under the Anti-Terrorism Law. In such cases, the path is a crime report to the Federal Police, together with the preserved documentation. Companies outside the obligated sectors of Law 9,613 do not report to COAF, but they can and should contact the Federal Police when there is evidence of a crime. The Federal Police itself notes that anonymous reports are processed more slowly; identifying yourself speeds up handling.