What are OFAC's Enforcement Guidelines?

OFAC's Enforcement Guidelines explain how a civil penalty is calculated when a violation occurs.

TL;DR

TL;DR: OFAC's Economic Sanctions Enforcement Guidelines, published at 31 CFR Part 501 Appendix A, define how penalties are calculated using a base amount adjusted by aggravating and mitigating factors.

How the calculation works

OFAC starts with a base amount tied to the violation, then adjusts it. Aggravating factors increase the penalty and include willful conduct, concealment, management involvement, and prior violations. Mitigating factors reduce it and include voluntary self-disclosure, cooperation, and an effective compliance program.

Why it matters

Civil penalties start at $356,000 per violation, so the difference between aggravating and mitigating factors is substantial. A company with a documented screening program is in a far better position than one with no program at all.

Practical takeaway

Run a screening step before payments and keep a record of each clean decision. sanctionsai.dev follows the SCREEN, SCORE, STOP, STAMP protocol, so every screen leaves a STAMP that supports a mitigating-factors argument if an issue ever arises.