OFAC Makes Technical Amendment to Applicable Schedule Amount for Sanctions Penalties

The Office of Foreign Assets Control made a technical amendment to the definition of “applicable schedule amount,” which establishes a base penalty for non-egregious sanctions violations cases that do not involve a voluntary self-disclosure. OFAC has periodically raised its “applicable schedule amount” to correspond to the agency’s civil monetary penalties, which are adjusted annually for inflation (see 2104090006). Under the new definition, the applicable schedule amount “will automatically rise with OFAC’s CMPs, removing the necessity of updating the applicable schedule amount on an annual basis,” the agency said. The change becomes effective Jan. 21.