Full breakdown of OFAC civil and criminal penalties, how they apply to autonomous agent transactions, and real-world examples.
For 2024, OFAC civil penalties start at $330,944 per violation or twice the transaction value, whichever is greater. For autonomous agents, each payment to a sanctioned counterparty is a separate violation. An agent processing 10 payments to the same wallet creates 10 separate violations.
The maximum civil penalty for each OFAC violation is $330,944 (2024 adjustment) or twice the transaction value. OFAC considers these factors in determining the actual penalty amount: (1) whether the violation was voluntarily disclosed, (2) the existence of a compliance program at the time of the violation, (3) the sophistication of the violator, (4) the harm to sanctions program objectives, (5) the violator's cooperation during the investigation.
For willful violations, criminal penalties can reach $1,000,000 in fines and up to 20 years imprisonment per violation. A willful violation means the person knew or had reason to know their actions violated sanctions.
An AI agent that screens before every payment is treated as having a documented compliance program. An agent that does not screen is treated as operating without controls, which is an aggravating factor. The difference can be the difference between a warning letter and a $330,944 penalty.
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