July 1: OFAC plays catch-up!

As expected, OFAC waited till the last second to update its civil monetary penalty statutory maximums. Adjustments were due by July under the Federal Civil Monetary Penalty Inflation Adjustment Act Enhancement Act of 2015, which compelled agencies who had ignored the Federal Civil Monetary Penalty Inflation Adjustment Act of 1990’s requirement to adjust penalties every 3 years.

Here are the old figures and the new, by statute:

OFAC’s Civil Monetary Penalties
 Statute  Old Maximum  New Maximum
 Trading with the Enemy Act (TWEA)  $65,000  $83,864
 International Emergency Economic Powers Act (IEEPA)  $250,000 or twice the transaction amount  $284,582 or twice the transaction amount 
 Foreign Narcotics Kingpin Designation Act (FNKDA)  $1,075,000  $1,414,020
 Antiterrorism and Effective Death Penalty Act (AEDPA)  $55,000 or twice the required retained amount  $75,122 or twice the required retained amount
 Clean Diamond Trade Act (CDTA)  $10,000  $12,856

 

 

 

 

 

 

 

 

 

Links:

OFAC Notice

Federal Register6775 Notice

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