The sanctions rely on authority granted by the International Emergency Economic Powers Act (IEEPA) and were signed by OFAC Director
Bradley Smith; under the Foreign Narcotics Kingpin Designation Act, OFAC can impose a civil-penalty maximum of $330,947 per violation (CRS IEEPA primer, https://crsreports.congress.gov/product/pdf/LSB/LSB10933; Treasury leadership page, https://home.treasury.gov/about/offices; OFAC penalty guidelines, https://ofac.treasury.gov/media/7066/download).