How OFAC penalties are calculated
How OFAC penalties are calculated
OFAC penalty calculation: (1) Determine if the violation is egregious or non-egregious. (2) Calculate the base penalty based on the statutory maximum ($330,944 or 2x transaction value). (3) Apply aggravating factors (increase). (4) Apply mitigating factors (decrease). (5) The result is the recommended penalty — subject to negotiation and settlement.