What is the OFAC framework for civil penalties?

OFAC's penalty framework is governed by its Economic Sanctions Enforcement Guidelines, which set a base amount and adjust it up or down.

TL;DR

TL;DR: The framework calculates a base penalty from the violation and adjusts it for aggravating and mitigating factors, with civil penalties starting at $356,000 per violation.

The base penalty

Under the Economic Sanctions Enforcement Guidelines, OFAC starts from a base penalty tied to the violation and its seriousness. Because sanctions carry strict liability, intent is not required for a violation to exist, though intent does influence how the penalty is adjusted.

Aggravating and mitigating factors

Aggravating factors include willful or reckless conduct and a weak compliance program, while mitigating factors include voluntary disclosure, cooperation, and strong controls. These adjustments can move the final amount meaningfully in either direction.

How to reduce your exposure

The strongest mitigation is a working screening control that fails closed. The 50 Percent Rule and the SDN List are handled automatically when every counterparty is checked before payment. SanctionsAI returns clean or flagged in under 100 ms across 947 OFAC-listed wallets and 19,218 SDN names, synced hourly.