While sanctions on Zimbabwe are generally regarded to be under the Zimbabwe Democracy and Economic Recovery Act, the stiffer sanctions that Tagwirei is busting are under the International Emergency Economic Powers Act (IEEPA) and are administered and regulated by the US Treasury Department’s Office of Foreign Assets Control (OFAC).
According to OFAC violating sanctions issued under the IEEPA carries steep civil and criminal implications. Section 1705 of IEEPA provides that it is unlawful for a person to violate, attempt to violate, conspire to violate, or cause a violation of any license, order, regulation, or prohibition issued under this Chapter.
Section 1705C provides that a person who willfully commits, attempts to commit, conspires to commit, or aids or abets in the commission of an unlawful act described in subsection A shall be fined not more than US$1 000 000, be imprisoned for not more than 20 years, or both.
Additionally, 50 USC §1705 Title X provides that a civil penalty may be imposed on any person who commits an unlawful act defined in subsection A in an amount not to exceed the greater of $250 000 or twice the amount of the prohibited transaction. This penalty applies per-violation, so the total fine can be steep.
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