OFAC Civil Penalty Glossary Part 1
Core terms for the monetary fines OFAC can impose for sanctions violations, regardless of intent.
TL;DR
TL;DR: A civil penalty is the monetary fine OFAC can impose for a sanctions violation, starting at $356,000 per violation. Because OFAC enforces strict liability, intent is not required for the penalty to apply.
What an OFAC civil penalty is
A civil penalty is a financial sanction imposed for violating OFAC regulations, distinct from a criminal prosecution. OFAC computes penalties using a base amount tied to the transaction, then adjusts for aggravating and mitigating factors. Penalties start at $356,000 per violation, and multiple violations can stack, so a pattern of unscreened payments can produce an enormous total exposure.
Why it matters for agent payments
An AI agent that pays a blocked wallet creates a violation with no human intent required. The penalty follows the transaction, not the agent's motive, so automation does not reduce the fine. The only reliable defense is to screen before the payment happens. The sanctionsai.dev API screens a counterparty in one HTTP call under 100 ms and returns a clean or flagged result, letting the agent block the transaction before it becomes a penalty event.
Terms covered in Part 1
- Strict liability: liability without intent or knowledge.
- Base penalty: the starting amount tied to the transaction value.
- Mitigating factor: a circumstance that can reduce the fine.