Significant Fines and Penalties

Violation of Export Control laws can subject individuals or institutions to civil or criminal sanctions. It is important to note that these penalties can be imposed on individuals as well as institutions.  The penalties vary depending on the circumstances (notably, whether it was a "knowing" or "willful" violation), but the penalties for even lesser violations can include jail time and/or fines.

• Export Administration Regulations

  Penalties for violating the Export Administration Regulations include:

  • Criminal: Fines of $50,000 - $ 1,000,000 or five times the value of export, whichever is greater, per violation and up to 20 years in prison.
  • Civil: Fines between $10,000 - $120,000 per violation.

• International Traffics in Arms Regulations

  Penalties for violating the International Traffics in Arms Regulations include:

  • Criminal: Fines up to $1,000,000 per violation and up to ten years in prison.
  • Civil: Fines of up to $500,000 per violation.

• Office of Foreign Assets Control (OFAC)

  Penalties for violating OFAC requirements include:

  • Criminal: Fines up to $1,000,000 and ten years in prison
  • Civil: $12,000 - $55,000 per violation.

  Additional penalties may include: loss of export privileges, exclusion from practice, and/or seizure/forfeiture of goods.