Background

The Office of Foreign Assets Control has issued a final rule adjusting its maximum civil monetary penalties for inflation, as follows, effective April 17.

- $1,548,075 (up from $1,529,991) for violations of the Foreign Narcotics Kingpin Designation Act and the Foreign Narcotics Kingpin Sanctions Regulations

- the greater of $311,562 (up from $307,922) or twice the amount of the underlying transaction for violations of the International Emergency Economic Powers Act and the Narcotics Trafficking Sanctions Regulations, the Weapons of Mass Destruction Trade Control Regulations, the Zimbabwe Sanctions Regulations, the Syrian 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 Assets Control 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 Global Magnitsky Sanctions Regulations, the Magnitsky Act Sanctions Regulations, the Western Balkans Stabilization Regulations, the Global Terrorism Sanctions Regulations, the North Korea Sanctions Regulations, and the Yemen Sanctions Regulations

- $91,816 (up from $90,743) per violation on any person who violates any license, order, or regulation issued under the Trading with the Enemy Act

- the greater of $82,244 (up from $81,283) 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

- $14,074 (up from $13,910) for violations of the Clean Diamond Trade Act and the Rough Diamonds Control Regulations

- $24,04 (up from $23,765) for failure to furnish information pursuant to 31 CFR 501.602 whether or not any other violation is alleged

- $60,115 (up from $59,413) for failure to furnish information pursuant to 31 CFR 501.602 where OFAC has reason to believe the apparent violation involves a transaction valued at greater than $500,000, whether or not any other violation is alleged

- $3,005 (up from $2,970) for late filing of a required report, whether set forth in regulations or a specific license, if filed within 30 days of the due date

- $6,0125 (up from $5,942) for late filing of a required report, whether set forth in regulations or a specific license, if filed more than 30 days after the due date

- $1,203 (up from $1,189) for late filing of a required report, whether set forth in regulations or a specific license, if the report relates to blocked assets, an additional penalty for every 30 days the report is overdue, up to five years

- $60,226 (up from $59,522) for failure to maintain records in conformance with the requirements of OFAC regulations or a specific license

For more information on export penalties and how to avoid them, please contact attorney Kristine Pirnia via email.

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