OFAC Civil Penalty

A monetary fine imposed for sanctions violations, starting at $356,000 per violation and adjusted annually for inflation.

TL;DR

TL;DR: An OFAC civil penalty is a monetary fine for a sanctions violation, starting at $356,000 per violation and applied under strict liability.

How penalties are set

OFAC civil penalties start at $356,000 per violation, and the amount can rise based on the circumstances. OFAC adjusts its penalty figures annually for inflation. Because the penalty is per violation, a single compliance failure that repeats across many transactions can multiply into a much larger total, which is why a systemic gap is so costly. The amount can also reflect aggravating factors like willful concealment or a repeat offense.

Strict liability means no intent needed

The most important feature of OFAC civil penalties is the liability standard. Strict liability means intent is not required: a party that did not know it was dealing with a sanctioned counterparty is still liable. The penalty attaches to the transaction, not to the party's state of mind. Penalties are assessed per violation, so the same bad payment repeated a thousand times is not one violation but many.

Penalties for agent payments

For AI agents, the per violation math is unforgiving. An agent that runs unscreened at high velocity can generate many violations in minutes. sanctionsai.dev prevents that by screening each counterparty before payment, returning ALLOW or BLOCK. The free tier offers 5 checks per day, and paid plans add a $10K legal-fee guarantee, so screening costs a fraction of even one penalty.