Background

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.

Statute

Existing penalty amount

Penalty amount as of Aug. 1

Trading with the Enemy Act

$65,000

$83,864

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

$1,075,000

$1,414,020

Clean Diamond Trade Act

$10,000

$12,856

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