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The Treasury Department’s Office of Foreign Assets Control has issued an interim final rule increasing the maximum amount of the civil monetary penalties that may be assessed for violations of five sanctions programs administered by OFAC. These changes will be applicable to civil penalties assessed after Aug. 1 where the associated violations occurred after Nov. 2, 2015.
Existing penalty amount
Penalty amount as of Aug. 1
Trading with the Enemy Act
International Emergency Economic Powers Act
Greater of $250,000 or twice the amount of the underlying transaction
Greater of $284,582 or twice the amount of the underlying transactions
Antiterrorism and Effective Death Penalty Act
Greater of $55,000 or twice the amount of which a financial institution was required to retain possession or control
Greater of $75,122 or twice the amount of which a financial institution was required to retain possession or control
Foreign Narcotics Kingpin Designation Act
Clean Diamond Trade Act