Export Control Penalties and Sanctions

Export Controls Penalties

Penalties

  Department of Commerce (EAR) Department of State (ITAR) Department of the Treasury (OFAC)
Civil Penalties
  • Fines of up to $250,000 per violation (or twice the amount of the transaction)
  • Suspension or debarment from government contracts
  • Revocation of export privileges
  • Fines of up to $500,000 per violation
  • Suspension or debarment from government contracts
  • Seizure and forfeiture of article
  • Revocation of export privileges
  • Fines of up to $250,000 per violation
  • Suspension or debarment from government contracts
Criminal Penalties
(willful violation)
Fines of $1 million per violation, up to 20 years imprisonment Fines of up to $1 million per violation, up to 10 years imprisonment and debarment Fines of up to $1 million per violation, up to 10 years imprisonment

 

Sanctions
There are severe sanctions, in addition to the criminal and civil penalties, that may be imposed for violations, including:

  • termination of export privileges
  • suspension and/or debarment from federal government contracting
  • loss of federal funds
  • voluntary disclosure of violations serves as a "mitigating factor" in deciding penalties.