Egregious case definition

Egregious case

OFAC's label for a particularly serious violation calling for a strong enforcement response, which sets a much higher starting penalty than a non-egregious case.

also known as

egregious violation

reviewed

2026-10-02

Cite this page

APA 7

Sanctions Evasion Reference. (2026, October 2). Egregious case. https://sanctionsevasion.org/reference/glossary/egregious-case/

Chicago

Sanctions Evasion Reference. “Egregious case.” Last reviewed October 2, 2026. https://sanctionsevasion.org/reference/glossary/egregious-case/.

BibTeX

@misc{ser-reference-glossary-egregious-case,
  author = {{Sanctions Evasion Reference}},
  title  = {Egregious case},
  year   = {2026},
  note   = {Last reviewed 2026-10-02},
  url    = {https://sanctionsevasion.org/reference/glossary/egregious-case/}
}

The date is when this page was last reviewed, not when it was first published.

Whether a case is egregious is decided from the general factors in OFAC’s Enforcement Guidelines. The Guidelines describe it as one that “represents a particularly serious violation of the law calling for a strong enforcement response”, and give particular weight to wilfulness or recklessness and to whether the conduct was known to the company.

The label matters mostly because of the base amount it sets. A non-egregious, self-disclosed case starts at one-half of the transaction value; an egregious case that was not self-disclosed starts at the applicable statutory maximum. That is why two settlements for similar conduct can differ by orders of magnitude, and why the releases on this site state the finding in their first lines. See how penalties are decided.

Where this term is used

What is a professional enabler? — A lawyer, accountant, formation agent or broker whose services are what makes a concealment structure work, and whose repeated involvement across unconnected clients is itself the evidence.
How do gaps in acquisition integration create sanctions exposure? — A company buys a foreign business and keeps running its systems separately, so the acquired unit's transactions never pass through the parent's sanctions screening until someone thinks to connect them.
What happens when sanctions-screening controls go untested? — A firm builds real geo-blocking or screening controls, then never independently tests whether they still work, so a bug, a disabled setting or a discontinued tool runs unnoticed for months or years.

Related terms

Voluntary self-disclosure — A self-initiated notification to OFAC of an apparent violation, made before or at the same time as OFAC or another authority discovers it, which lowers the base penalty.
Strict liability — Civil liability that does not depend on knowing or having reason to know a transaction was prohibited. OFAC applies it, and the UK's OFSI has since 15 June 2022.
Tolling agreement — An agreement by a party under investigation to extend or suspend the statute of limitations, giving the regulator more time to finish before a deadline would otherwise bar action.

Sources

Economic Sanctions Enforcement Guidelines, Appendix A to 31 CFR Part 501. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026. Sections I (definitions), II (responses), III (general factors), V.B (penalty calculation).

Civil Penalties and Enforcement Information. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026.