OFAC shuffles sanction fines into a neat little binder
Published Date: 9/25/2026
Rule
Summary
The Treasury’s Office of Foreign Assets Control (OFAC) is rolling out new Sanctions Penalties Regulations that gather all penalty rules for breaking U.S. sanctions into one easy-to-find spot. This update doesn’t change any fines but makes it simpler for people and businesses to understand the rules and keep up with inflation adjustments. The new rules kick in on September 25, 2026, so everyone affected should get ready to check out the streamlined penalties info.
Analyzed Economic Effects
5 provisions identified: 3 benefits, 2 costs, 0 mixed.
IEEPA Civil and Criminal Penalties Defined
Under the new regulations, civil monetary penalties under the International Emergency Economic Powers Act (IEEPA) may be up to the greater of $377,700 or twice the value of the transaction that is the basis of the violation. Criminal penalties for willful violations can include fines up to $1,000,000 and, for natural persons, imprisonment for up to 20 years (willfulness is the required mens rea under 50 U.S.C. 1705(c)).
Voluntary Self-Disclosure Reduces Penalties
When OFAC learns of a violation through a voluntary self-disclosure, the Regulations state that base penalties are halved. This reduction applies in OFAC's consideration of civil monetary penalties.
Civil Penalties Adjust Annually for Inflation
The Regulations make civil penalty amounts subject to adjustment for inflation under the Federal Civil Penalties Inflation Adjustment Act of 1990 and the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015; agencies must adjust CMPs annually using the formula described in the 2015 Act. Over time, maximum civil penalties may increase annually due to these inflation adjustments.
Penalties Consolidated into Single Rule
OFAC added a new Sanctions Penalties Regulations part (part 505) that gathers previously scattered penalties information into one location and standardizes cross-references. The change is effective September 25, 2026, and is intended to make penalty rules easier to find and to ease compliance with inflation adjustments.
OFAC to Publish Penalty Outcomes Monthly
OFAC will make available to the public, not less frequently than monthly on its website, certain civil penalties information: for entities — name and location, sanctions program(s), brief description of the violation, whether it resulted in a settlement or penalty, whether it was voluntarily disclosed, and the penalty or settlement amount; for individuals — aggregate counts, programs involved, descriptions, settlement/penalty outcomes, and amounts. The designated medium for release is OFAC's website: https://ofac.treasury.gov.
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Key Dates
Department and Agencies
Related Federal Register Documents
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The U.S. Treasury’s OFAC just updated its sanctions list on October 5, 2026. Some people had their blocked property unlocked and were removed from the blacklist, while others had their info updated but remain blocked. These changes affect who can access money or property under U.S. rules, so watch for the latest details if you’re involved.
2026-20526, Notice of OFAC Sanctions Actions
The U.S. Treasury’s OFAC just updated its sanctions lists by unblocking some people and removing their names from the banned list. They also cleaned up duplicate entries and updated info on others who remain blocked. These changes affect individuals and entities tied to sanctions, with some unblocked as of July 27, 2026, meaning their assets are no longer frozen.
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