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.
