OFAC (Office of Foreign Assets Control, US Department of Treasury), Arrests and Penalties

Export Administration Regulations:

  • Criminal penalties or violations may result in a fine up to or greater than $1 million. A fine of $250,000 will be given to anyone involved, as well as imprisonment for up to ten years for each given violation.  
    • Export privileges denial and confiscation of goods


  • Across public enforcement actions, OFAC gained approximately $23.5 million in monetary penalties/settlements.
  • Across public enforcement actions pre-Covid 19 pandemic, OFAC gained approximately $1.3 billion in monetary penalties/settlements.
    • Covid-19 had impacted the OFAC operations and essentially forced OFAC to mainly only handle a large number of politically centered sanctions actions when there were no longer substantial enforcement cases to be handled.

-Sanction in Iran

  • The “Maximum Pressure” campaign against Iran was resumed throughout 2020 with the Trump administration, however now with some understanding for Iran's struggle during the peak of the pandemic.
    •  Iran Gross Official Reserves from 2000-2017 being $70 billion
    • Iran Gross Official Reserves in 2018 being $122.5 billion
    • Iran Gross Official Reserves in 2019 being $12.4 billion
    • Iran Gross Official Reserves in 2020 being $4 billion
    • Goal of Biden administration is to give Iran relief sanctions and if it goes back to the 2015 nuclear deal, to inject millions of dollars.
  • Iran's economy had been subject to “secondary sanctions” involving mining, construction, manufacturing, etc.
  • OFAC announced that they will not issue sanctions in Iran in relation to certain medicines, medical devices, and products designed for sanitation or hygiene. Some of these products include, but are not limited to diapers and other infant care products, hand sanitizer, soap, respirators, etc.
    • These are sanctions that are exceptions and are only to be used in the country of Iran- not for export from Iran.


  • During October of 2020, it was identified that the financial sector of Iran was as subject to the sectoral sanctions.
  • “Maximum Pressure” campaign detaches Iran's financial sector which is harmful for the foreign companies that do business with the financial sector of Iran or financial institutions of Iran.
    • Secondary sanctions typically target foreign companies that do business with the Iranian financial sector or institutions.

Sanctions Against Money Laundering

  • One of the most well-known drug money launderers, Nidal Waked, was arrested in May of 2016. OFAC took action by labeling Waked and other leaders involved as Specially Designated Narcotics Traffickers. OFAC targeted other associates of Waked and many other companies that have history with companies associated with drug money laundering such as S.A., Vida (zona Libre) S.A., Balboa Bank & Trust, etc.
  • OFAC is issuing three various general licenses that allow transactions to take place, however they under limited time periods with entities that are ruled by the Waked network.

-D. Russian Pipeline Projects

  • Throughout 2020, the Trump Administration made its efforts to put a stop to the completion of the Russian Pipeline projects. These Russian pipelines are meant to eventually reach through the entirety of Europe and through Ukraine. The 2020 NDAA which imposes sanction on pipelines along with other various sanctions are what essentially caused the delay in the projects. Throughout 2020, the U.S. government truly tried its best to finally put an end to them in order to finish up these projects that had been further delayed due to imposed sanctions and construction.

-OFAC arrests and sanctions can become very complicated and have extremely detrimental consequences. Please our office today to obtain legal advice and guidance.

It is advisable to seek legal guidance from our office today as we strive to help guide you with your specific case. 

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