Nonetheless, OFAC determined that the total base penalty for all of the alleged violations was $17,018,443. In arriving at that amount, OFAC considered the following aggravating factors in concluding that PayPal's actions, although deemed to be non-egregious violations of the Iranian, Cuban, Sudanese and Global Terrorism sanctions programs, constituted an egregious violation of the WMDP sanctions regulations: Somewhat offsetting these aggravating factors, OFAC found the following to be mitigating factors : OFAC's announcement of its settlement with PayPal is significant. Whereas much of the publicity surrounding the agency's recent enforcement actions has been focused on banks and other financial institutions that have stripped identifying information from fund transfer documents to avoid detection of transactions involving persons in sanctioned countries, OFAC's settlement with PayPal may indicate a new, heightened focus on the payments industry and payments processors.