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Appendix A to Part 501—Economic Sanctions Enforcement Guidelines

Date issued: Jan. 13 2023

Last substantive commentary amendment:
Jan. 12 2024

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Appendix A to Part 501 - Economic Sanctions Enforcement Guidelines.

 

Note:


This appendix provides a general framework for the enforcement of all economic sanctions programs administered by the Office of Foreign Assets Control (OFAC).


I. Definitions


A. Apparent violation means conduct that constitutes an actual or possible violation of U.S. economic sanctions laws, including the International Emergency Economic Powers Act (IEEPA), the Trading With the Enemy Act (TWEA), the Foreign Narcotics Kingpin Designation Act, and other statutes administered or enforced by OFAC, as well as Executive orders, regulations, orders, directives, or licenses issued pursuant thereto.


B. Applicable schedule amount means:

1. $1,000 with respect to a transaction valued at less than $1,000;

2. $10,000 with respect to a transaction valued at $1,000 or more but less than $10,000;

3. $25,000 with respect to a transaction valued at $10,000 or more but less than $25,000;

4. $50,000 with respect to a transaction valued at $25,000 or more but less...

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TURBOFAC Commentary (682 words)

Notes:


1) Given the scope of these comments as being oriented primarily toward the scope and operation of the sanctions law for the purposes of compliance with them, a full analysis of the entirety of the enforcement guidelines is beyond the scope of this note. Refer generally to FR Notice Addressing Regulated Community Comments re: OFAC Enforcement Guidelines (2009), for OFAC commentary on different aspects of the guidelines.


2) Many of the topics addressed in these guidelines, and OFAC's shifting practices with respect to them, are indirectly addressed further by enforcement actions. The Research System contains several tags designed to assist with a better understanding of how OFAC handles certain enforcement guideline-specific issues. Examples include:


* Voluntary self-disclosure credit (Section I.I).


Search by enforcement actions for which VD credit was given and those for which it was not. Voluntary disclosure credit issues are discussed in, e.g., Civil Enforcement...