OFAC Revises Applicable Schedule Amount for Sanctions Penalties

The Office of Foreign Assets Control is amending the base civil penalty amount for certain sanctions violations to reflect inflation adjustments for its civil monetary penalties, a notice released Aug. 10 said. The change, which takes effect Aug. 11, revises the definition for OFAC’s “applicable schedule amount,” which establishes a base penalty for non-egregious sanctions violations cases that do not involve a voluntary self-disclosure.

OFAC revised two sections of the applicable schedule amount. For transactions valued at $100,000 but less than $200,000, the applicable schedule amount will be $200,000; for transactions valued greater than $200,000, the amount is $307,922, OFAC said. OFAC said these changes were not required, but it made them so that its base penalties “continue to correspond appropriately” to the agency’s civil monetary penalties, which are adjusted annually for inflation. More information on OFAC’s applicable schedule amount can be found in the Code of Federal Regulations.