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OFAC Adjusts Civil Monetary Penalties

Friday, February 10, 2017
Sandler, Travis & Rosenberg Trade Report

The Office of Foreign Assets Control has issued a final rule adjusting its maximum civil monetary penalties for inflation, as follows. Any increases will apply to penalties assessed after the effective date regardless of whether the underlying violation occurred before that.

- $1,437,153 for violations of the Foreign Narcotics Kingpin Sanctions Regulations (effective Jan. 15, 2017)

- $1,333,312 for violations of the Terrorism Risk Insurance Program

- greater of $289,238 or twice the amount of the underlying transaction for violations of the Iranian Assets Control Regulations, the Narcotics Trafficking Sanctions Regulations, the Sudanese Sanctions Regulations, the Weapons of Mass Destruction Trade Control Regulations, the Zimbabwe Sanctions Regulations, the Syrian Sanctions Regulations, the Cote d’Ivoire Sanctions Regulations, the Weapons of Mass Destruction Proliferators Sanctions Regulations, the Darfur Sanctions Regulations, the Democratic Republic of the Congo Sanctions Regulations, the Belarus Sanctions Regulations, the Lebanon Sanctions Regulations, the Iranian Transactions and Sanctions Regulations, the Iranian Financial Sanctions Regulations, the Hizballah Financial Sanctions Regulations, the Iraq Stabilization and Insurgency Sanctions Regulations, the Western Balkans Stabilization Regulations, the Global Terrorism Sanctions Regulations, and the Terrorism Sanctions Regulations (effective Jan. 15, 2017)

- $85,236 per violation on any person who violates any license, order, or regulation issued under the Trading with the Enemy Act (effective Jan. 15, 2017)

- greater of $76,351 or twice the amount of which a financial institution was required to retain possession or control for violations of the Foreign Terrorist Organizations Sanctions Regulations (effective Jan. 15, 2017)

- $13,066 for violations of the Rough Diamonds Control Regulations (effective Jan. 15, 2017)

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