Penalties for Non-Compliance

State Department (ITAR)

  • Criminal Penalties:  up to $1M per violation and up to 10 years in prison.
  • Civil Penalties:  seizure and forfeiture of articles, revocation of exporting privileges, fines of up to $500K per violation.

 

Commerce Department (EAR)

  • Criminal Penalties:  $50K-$1M or five times value of export (whichever is greater), per violation; up to 10 years in prison.
  • Civil Penalties:  loss of export privileges, fines of $10K-$120K per violation.

 

Treasury Department (OFAC)

  • Criminal Penalties:  up to $1,000,000 per violation and up to 10 years imprisonment.
  • Civil Penalties:  $12,000 to $55,000 fines (depending on applicable law) per violation.
  • Violation of specific sanctions laws may add additional penalties.

 

NOTE:  PENALTIES FOR VIOLATIONS CAN APPLY TO BOTH INDIVIDUALS INVOLVED IN THE VIOLATION AND THE INSTITUTION!

  • Loss of "exporting" privileges (usually for 30-90 days) could cripple a university's normal activities.
  • Violations will jeopardize federal funding for the university and for the individual.
  • Violations will generate negative media attention.