Penalties / Sanctions

Who Can Be Penalized? INDIVIDUALS and/or the ORGANIZATION!

Violations of International Traffic in Arms Regulations (ITAR)

Criminal Penalties (for willful violation):  entity of up to $1,000,000 for each violation; individuals may be subject to a fine of up to $250,000 or imprisonment of up to ten years, or both, for each violation.

Civil Penalties: entity up to $1,094,010 for each violation; individuals may be subject to fines of up to $1,094,010 for each violation.  In addition, suspension or debarment from government contracts; seizure or forfeiture of the item; and/or revocation of export privileges.

Violations of the Export Administration Regulations (EAR)

Criminal Penalties (for willful violation): may result in the institution paying a fine of up to $1,000,000 or five times the value of the exports (whichever is greater) for each violation; and the individual may be fined up to $250,000 or be imprisoned for up to ten years, or both, for each violation.

Criminal Penalties (for knowing violation): may result in the institution paying a fine of up to the greater of $50,000 or five times the value of the exports for each violation; and the individual may be fined up to the greater of $50,000 or five times the value of the exports or be imprisoned for up to five years, or both, for each violation.

Civil Penalties:include $12,000 for each violation, except that the fine for violations involving items controlled for national security reasons is up to $120,000 for each violation; suspension or debarment from government contracts; seizure or forfeiture of the item; and/or revocation of export privileges.

Additionally, for each violation, any or all of the following sanctions may be imposed:

  • The denial of export privileges; and/or 
  • The exclusion from exporting practice; and/or 
  • Loss of federal funds
  • Seizure/Forfeiture of goods.

Violations of Foreign Asset Control Regulations

International Emergency Economic Powers Act (IEEPA) Penalties

  • Civil penalty: may result in the institution paying a fine of up to $284,582 per violation or twice the transactional value whichever is greater; and the individual may be fined up to $284,582 per violation or twice the transactional value whichever is greater.;
  • Criminal penalty: may result in the institution paying a fine of up to $1,000,000 per violation; and the individual may be fined up to $1,000,000 or twenty years incarceration, or both per violation.

Additionally, for each violation, any or all of the following sanctions may be imposed:

  • The denial of export privileges; and/or
  • The exclusion from exporting practice; and/or
  • Seizure/Forfeiture of goods.

Trading with the Enemy Act (TWEA) Penalties (Cuba and North Korea)

  • Civil penalty: $65,000 per violation
  • Criminal penalty: $1,000,000 per violation and up to 10 years incarceration

Violations of Nuclear Export Control Regulations

Criminal sanctions for willful violations and civil penalties may be imposed.

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