By · · last updated 2026-08-01
The base civil penalty starts at $356,000 per violation. How the number works, what mitigates it, and why strict liability makes agents the riskiest surface.
Every OFAC discussion eventually hits the same number: $356,000. Here is what it actually means.
Civil penalties start at $356,000 per violation (the base rate; OFAC adjusts it). That is the starting point before aggravating factors push it up — and before mitigating factors pull it down. For agents executing many payments, the per-violation math compounds fast.
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OFAC's Enforcement Guidelines reward: voluntary self-disclosure (the biggest factor), a documented compliance program, and cooperation. An agent that screens before every payment and logs every result is the kind of program that turns a potential maximum penalty into a mitigated one.
The standard is strict: intent does not matter, timing does not matter. An agent that paid a sanctioned wallet at 3 AM is the operator's violation — "the agent didn't know" is not a defense.
A year of screening at $19/mo is $228. One violation starts at $356,000. The asymmetry is the entire argument for the screen — and it is the whole product.
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