OFAC penalties vary significantly based on multiple factors. Civil penalties can reach the greater of $330,947 per violation or twice the transaction value (these amounts adjust periodically for inflation). Criminal penalties for willful violations can include fines up to $1 million and imprisonment up to 20 years. However, actual penalties depend on case specifics: whether violations were willful or non-willful, whether you had compliance programs in place, transaction value, how many violations occurred, and whether you self-disclosed. OFAC’s enforcement guidelines outline aggravating and mitigating factors. I reviewed numerous settlement cases on ofacblockedfundslawyers.com and penalties ranged from cautionary letters (no fine) to millions of dollars. Companies with robust compliance programs that self-disclose and cooperate typically receive significantly reduced penalties. The risk isn’t just financial – reputational damage and operational disruption can be substantial.
