Kingsfield · Research · International Trade & Sanctions

What are the penalties for violating sanctions issued under the International Emergency Economic Powers Act (IEEPA)?

Published 2026-06-23 · U.S. federal law

50 U.S.C. § 1705 makes it unlawful to violate, attempt to violate, conspire to violate, or cause a violation of any license, order, regulation, or prohibition issued under IEEPA, and sets the civil and criminal penalties for doing so.

The answer

The prohibition and penalties

50 U.S.C. § 1705 makes it unlawful to violate, attempt or conspire to violate, or cause a violation of any license, order, regulation, or prohibition issued under IEEPA. The section authorizes a civil penalty and, for willful violations, criminal fines and imprisonment.

Strict-liability exposure

The civil penalty under Section 1705 attaches to the violation itself and does not require proof of willfulness, which is why OFAC pursues civil penalties on a strict-liability basis. Criminal liability is reserved for willful conduct.

The judged input

What the AI drafted

Submitted to the judge

This is an excerpt from a draft sanctions-compliance memo — the kind of work product a lawyer generates with a legal-AI drafting tool, then has to stand behind. Kingsfield does not write it; it rules on the citations the model put in it. This draft cites two authorities; one of them is wrong.

AI draft excerpt — sanctions-compliance memo

The Company faces meaningful enforcement exposure if any covered transaction proceeds without authorization. Under 50 U.S.C. § 1705, it is unlawful to violate, attempt to violate, conspire to violate, or cause a violation of any license, order, regulation, or prohibition issued under IEEPA, and such conduct carries both civil and criminal penalties. We note that the civil penalty applies on a strict-liability basis, so the absence of intent will not defeat liability. The penalty structure for these violations is set out in 50 U.S.C. § 1702.

The judge ruled on every citation as the draft used it — it accepted 50 U.S.C. § 1705 and rejected 50 U.S.C. § 1702. Here is why.

The verdict

How Kingsfield ruled

Ruled 2026-06-23

Each citation in the draft above was submitted to the Kingsfield judge and ruled against the primary-law corpus — Accept, Reject, or Inconclusive, per citation. These are live verdicts, not editorial. Each card shows the claim the draft made and the verbatim authority the verdict was rendered against.

Accept50 U.S.C. § 1705

The draft claimed: It is unlawful to violate, attempt to violate, conspire to violate, or cause a violation of any license, order, regulation, or prohibition issued under IEEPA, and such violations carry civil and criminal penalties.

“§ 1705 A civil penalty may be imposed on any person who commits an unlawful act described in subsection (a) in an amount not to exceed the greater of—”

Cite found; proposition supported by the cited text.

Reject50 U.S.C. § 1702

The draft claimed: Section 1702 sets the civil and criminal penalties imposed for violating a license, order, or regulation issued under IEEPA.

Cite found, but the cited text does not support the claim. 50 U.S.C. 1702 grants the President authority to investigate, regulate, or prohibit transactions and block property during a declared emergency; the penalties for violations are set at 50 U.S.C. 1705. Regenerate with the correct authority.

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Kingsfield rules on every citation, quote, and proposition your AI produces, against the primary law we cover. Accept, Reject, or Inconclusive, per citation, with a signed Audit Capsule.

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This page is legal information, not legal advice, and does not create an attorney-client relationship. The draft shown is an illustration of a typical AI answer; verdicts reflect the cited authority in the Kingsfield corpus as of the ruling date shown above.