Five Core Components of OFAC Sanctions Compliance

A structured, documented compliance programme can help organisations identify risks earlier, support effective controls and strengthen day-to-day compliance decision-making.

Consequences of OFAC sanctions violations

The stakes can be significant. Where sanctions violations occur, OFAC can issue civil monetary penalties that range from thousands of dollars into hundreds of millions, with the final amount influenced by factors such as the value of the underlying transaction, voluntary self-disclosure, whether the conduct is considered egregious and the strength of the compliance programme.

Egregious (adjective)
[ih-gree-juhs, -jee-uhs]
extraordinary in some bad way; glaring; flagrant.
www.dictionary.com

OFAC penalty criteria:

• The “Applicable Schedule Amount” acts as a baseline cap for non-egregious cases – these run from $1,000 to $200,000
• The “Statutory Maximum”, applied to egregious cases, is “$377,700 or twice the amount of the underlying transaction”* 

In the case of a voluntary self-disclosure, penalty amounts are significantly reduced (typically by half). Once a base penalty is established, OFAC also considers General Factors to determine penalty amounts:

1. Wilful or reckless violation of law
2. Awareness of conduct at issue
3. Harm to sanctions programme objectives
4. Individual characteristics
5. Compliance programme
6. Remedial response
7. Cooperation with OFAC
8. Timing of apparent violation in relation to imposition of sanctions
9. Other enforcement action
10. Future compliance/deterrence effect
11. Other relevant factors on a case-by-case basis

Sound complicated? The below offers an illustrative and simplified example of how OFAC determines penalties (for educational purposes only, not accounting for General Factors).

Further detail on OFAC decision making and civil monetary penalty amounts is available here.

LexisNexis® Risk Solutions helps organisations operationalise OFAC’s framework with data-driven insights, advanced analytics and scalable screening capabilities.

Our watchlist screening solutions can help you:

• Streamline customer and transaction screening workflows
• Ensure adherence to OFAC and other global regulatory requirements
• Balance compliance mandates with seamless customer acquisition
• Minimise false positives and operational inefficiencies
• Enhance the effectiveness of compliance and customer management processes

*For sanctions implemented under the International Emergency Economic Powers Act (IEEPA) only. Different statutory maximums may apply, depending on the statute underpinning the sanctions violated.

¹U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC). Introduction to the Office of Foreign Assets Control. U.S. Department of the Treasury, Washington, DC, (June 1, 2026). OFAC Introduction document (PDF)