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OFAC Revises Applicable Schedule Amount for Sanctions Penalties

The Office of Foreign Assets Control amended the base civil penalty amount for certain sanctions violations to reflect inflation adjustments for its civil monetary penalties, it said in a notice. The change, effective April 12, revises the definition for OFAC’s…

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“applicable schedule amount,” which establishes a base penalty for non-egregious sanctions violations cases that do not involve a voluntary self-disclosure. For transactions valued at $200,000 or more, the applicable schedule amount will be $311,562, which is the maximum civil monetary penalty amount for a violation of the International Emergency Economic Powers Act, OFAC said. The agency said these changes were not required but done so that its base penalties “correspond appropriately” to OFAC’s civil monetary penalties, which are adjusted annually for inflation. OFAC last revised the applicable schedule amount definition in August 2020 (see 2008100012).