No formal de minimis exception exists. Technically even small violations are actionable. That said, OFAC has limited resources and tends to prioritize larger cases and egregious conduct. But I’ve seen published enforcement actions for violations under $10,000, so don’t assume small means safe. What matters more than dollar amount is the nature of the violation – terrorism financing or weapons proliferation programs get scrutiny regardless of amount. If you have good compliance procedures and discover a small inadvertent violation, you might get a warning letter rather than a penalty. I reviewed enforcement patterns at this link ofacblockedfundslawyers.com and size matters less than intent and compliance culture.
