The Office of Foreign Assets Control (OFAC) has changed the base civil penalty amount for certain sanctions violations. This was done in order to reflect inflation adjustments for its civil monetary penalties. In a notice, the OFAC’s definition of “applicable schedule amount” was revised. This establishes a base penalty for non-egregious sanctions violation cases that do not involve a voluntary self-disclosure.

In the notice, OFAC stated “in the case of transactions valued at $200,000 or more, the applicable schedule amount is now $311,562, which corresponds with the current maximum CMP amount for a violation of the International Emergency Economic Powers Act.”

The changes were not required but were done so that base penalties to “correspond appropriately” to OFACs civil monetary penalties, which get adjusted each year for inflation. The last time that the OFAC revised the applicable schedule amount definition was in August 2020.

This technical amendment takes effect April 12. For further questions on civil penalty amounts for sanction violations, contact Mohawk Global Trade Advisors.

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