Notice of new OFAC Civil Penalties Interim Policy

On October 16, 2007, the President signed into law the International Emergency Economic Powers Enhancement Act, Pub. L. No. 110-96, which, inter alia, increased the maximum civil penalty applicable to violations of orders or regulations issued under IEEPA .  These amounts are applicable to all violations with respect to which enforcement action is pending or commenced on or after October 16, 2007.  OFAC interprets this provision to mean that the new civil penalty provisions apply to all violations with respect to which a Final Penalty Notice had not been issued as of October 16, 2007.   Notwithstanding this general interim policy, OFAC will handle certain identified categories of cases in the manner indicated in the Interim Policy.