𝗢𝗙𝗔𝗖 𝗝𝘂𝘀𝘁 𝗥𝗲𝗹𝗲𝗮𝘀𝗲𝗱 𝗮𝗻 𝗨𝗽𝗱𝗮𝘁𝗲𝗱 𝗜𝗻𝘁𝗿𝗼𝗱𝘂𝗰𝘁𝗶𝗼𝗻 𝗚𝘂𝗶𝗱𝗲 - June 1, 2026.
For compliance officers, legal counsel, and international trade professionals, here are the key details worth noting in this latest version:
📌 Updated Civil Penalty Figure The maximum civil monetary penalty per IEEPA violation, as of January 15, 2025, stands at $377,700 per apparent violation — adjusted annually for inflation.
📌 Extended Enforcement Statute of Limitations OFAC may now commence enforcement actions for IEEPA- or TWEA-based violations within 10 years of the latest violation date (where that date falls after April 24, 2019). Other violations carry a five-year window.
📌 Secondary Sanctions — Expanding Scope The guide reaffirms that the explicit use of secondary sanctions targeting non-U.S. persons has become increasingly common — no longer limited to Iran-focused programs.
📌 The 50% Rule — Still a Blind Spot for Many A company not appearing on the SDN List can still be fully blocked if sanctioned persons own 50% or more of it, directly or indirectly. Due diligence must go beyond name-matching.
📌 Voluntary Self-Disclosure Incentive Reaffirmed Proactively disclosing apparent violations can reduce proposed civil penalties by 50%. Full report expected within 180 days of initial notification.
📌 Recordkeeping: 10-Year Obligation All transactions subject to OFAC regulations must be documented and retained for 10 years — including those processed under a license.
This updated guide is a timely reminder to revisit your screening protocols, KYC procedures, and internal reporting timelines.
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