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OFAC Proposes Inflationary Hikes to Max Sanctions Penalty Amounts

The Office of Foreign Assets Control is proposing to raise for inflation the maximum amount of civil monetary penalties assessable under five U.S. sanctions programs. The proposed rule (here), which would take effect Aug. 1, would make the following changes:

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  • Raise the penalty ceiling under the Trading with the Enemy Act from $65,000 to $83,864 per violation
  • Raise the top penalty amount under the International Emergency Economic Powers Act from the greater of $250,000 or twice the transaction amount, to the greater of $284,582 or twice the transaction amount
  • Raise the penalty ceiling under the Foreign Narcotics Kingpin Designation Act from $1.075 million to $1,414,020
  • Lift the maximum penalty under the Clean Diamond Trade Act from $10,000 to $12,856.

OFAC is accepting comments until Aug. 1.

(Federal Register 07/01/16)