US OFAC Sanctions Compliance Framework 501 App. A (III): Expect enforcement to weigh the General Factors: willfulness, awareness, harm, compliance program, remediation and cooperation

What does 501 App. A (III) require?

31 CFR Part 501 Appendix A, Sections II to IV: OFAC may respond with no action, a request for information, a cautionary letter, a finding of violation, a civil penalty or criminal referral; it weighs General Factors A willful or reckless conduct, B awareness, C harm to program objectives, D individual characteristics, E the existence and adequacy of a risk-based compliance program, F remedial response, G cooperation (including tolling agreements), H timing, I other enforcement, J deterrence and K other factors; failing to furnish information or keep records, and late reports, carry separate penalties, the blocked-asset late-report penalty now running up to 10 years.