In response to last year’s steep penalty increases for sanctions violations, OFAC has issued Enforcement Guidance on how it will apply civil fines that can now reach up to $250,000 per violation. The new Guidance, which takes effect immediately, introduces several general factors the agency will take into consideration in determining penalties for violations, including the existence of a compliance program, the financial situation and business sophistication of the company, and whether the company voluntarily disclosed the violation. Based on these and other factors, OFAC will cap fines for non-egregious cases that are voluntarily disclosed at $125,000 per violation.