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OFAC Increases Civil Monetary Penalties

Monday, March 19, 2018
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.

- $1,466,485 (up from $1,437,153) for violations of the Foreign Narcotics Kingpin Designation Act and the Foreign Narcotics Kingpin Sanctions Regulations

- $1,360,525 (up from $1,333,312) for violations of the Terrorism Risk Insurance Program

- the greater of $295,141 (up from $289,238) or twice the amount of the underlying transaction for violations of the International Emergency Economic Powers Act and 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 Magnitsky Act Sanctions Regulations, Western Balkans Stabilization Regulations, the Global Terrorism Sanctions Regulations, and the Terrorism Sanctions Regulations

- $86,976 (up from $85,236) per violation on any person who violates any license, order, or regulation issued under the Trading with the Enemy Act

- the greater of $77,909 (up from $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

- $13,333 (up from $13,066) for violations of the Clean Diamond Trade Act and the Rough Diamonds Control Regulations

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