OFAC Penalties

OFAC, in conjunction with the Department of Justice, can impose criminal penalities against corporations, officers and directors, and individuals involved for willful violations of U.S. sanctions programs.  Willful violations may include those that result from conscious disregard or refusal to comply with OFAC requirements or from self-blinding (i.e., purposefully NOT asking questions of customers that will help you determine their legitimacy).  OFAC also has independent authority to impose civil penalties for violations. The maximum penalties for each sanctions program are listed below:

Balkans

Criminal penalties

• Corporations: $500,000 or twice the pecuniary gain, whichever is greater
• Individuals: $250,000 or twice the pecuniary gain, whichever is greater
• Individuals: 10 years in prison

Civil penalites

• Corporations / Individuals: $11,000 per violation

Sudan

Criminal penalties

• Corporations: $500,000
• Individuals: $250,000
• Individuals: 10 years in prison

Civil penalites

• Corporations / Individuals: $11,000 per violation

Syria

Criminal penalties

• Corporations: $500,000
• Individuals: $250,000
• Individuals: 10 years in prison

Civil penalites

• Corporations / Individuals: $11,000 per violation

Terrorists

Criminal penalties

• Corporations: $500,000
• Individuals: $250,000
• Individuals: 10 years in prison

Civil penalites

• Financial institutions: $55,000 per violation or twice the amount that should have been blocked or reported, whichever is greater
• Corporations / Individuals: $11,000 per violation

Zimbabwe

Criminal penalties

• Corporations: $500,000 or twice the pecuniary gain, whichever is greater 
• Individuals: $250,000 or twice the pecuniary gain, whichever is greater
• Individuals: 10 years in prison

Civil penalites

• Corporations / Individuals: $11,000 per violation