Penalties for violating U.S. export control regulations and sanctions can apply to individuals, companies and institutions.
Voluntary disclosures (or self-disclosures) by companies who believe they may have violated applicable export controls generally result in "settlement agreements". Because disclosures generally evidence intent to comply with U.S. export control requirements, and demonstrate the ability to identify violations and correct discrepancies,
they rarely lead to criminal prosecution, instead reducing most cases fines and other administrative penalties.
Criminal and Civil Penalties under ITAR, EAR and OFAC
Penalties are classified as either criminal, or civil, with intent being the crucial differentiator. Incarceration applies only in criminal cases.
- International Traffic in-Arms Regulations (ITAR) more +
- Export Administration Regulations (EAR) more +
- Office of Foreign Assets Control (OFAC) more +
There are also four categories of administrative penalties that can be applied, alone, or in concert with regulatory penalties. more +