OFAC Enforcement Tracker

The OFAC Enforcement Tracker is an independent, searchable database of OFAC enforcement cases, civil penalties, and settlements published from 2003 to the present. OFAC is the office within the U.S. Department of the Treasury responsible for administering and enforcing U.S. economic and trade sanctions. The tracker lets users search and filter cases, review penalty details, identify the sanctions programs involved, and access original OFAC enforcement documents.

The tracker aggregates publicly available OFAC information for research and informational purposes. It is not affiliated with OFAC or the U.S. Department of the Treasury, does not provide legal advice, and should not replace review of the official source documents.

All tracker data is extracted and standardized from official OFAC enforcement documents published by the U.S. Department of the Treasury. The database covers documents issued from 2003 to the present, and each case links to its original OFAC source.

The tracker is updated whenever OFAC publishes a new enforcement action document. Each new case is added automatically once the official document is released.

Use the search bar to find OFAC enforcement actions by company name, such as “Binance,” and view all matching cases in the database. You can also filter cases by year, date range, sanctions program, or penalty amount.

Each case is converted into a standardized view using the information available in the original OFAC document. Available fields may include the company or individual name, address, country, industry, sanctions programs, apparent violations, violation summary, voluntary self-disclosure status, penalty calculations, final settlement amount, resolution, case summary, and original source documents.

Yes. Each case view includes a link to the original OFAC enforcement PDF published by the U.S. Department of the Treasury. The source document may contain the full violation details, penalty calculations, settlement terms, compliance commitments, and other information released by OFAC.

An OFAC enforcement action is an administrative response to an actual or apparent violation of U.S. sanctions regulations. Depending on the circumstances, OFAC may take no action, issue a cautionary letter or Finding of Violation, impose a civil monetary penalty, enter into a settlement, or refer the matter to another agency for possible criminal investigation.

An OFAC civil penalty is a monetary penalty imposed for an actual or apparent violation of U.S. sanctions regulations. OFAC generally applies strict liability, meaning a person or company may face civil liability even without knowing that the conduct was prohibited. The final amount depends on the applicable law, the seriousness of the conduct, voluntary self-disclosure, cooperation, compliance controls, and other enforcement factors.

A civil OFAC penalty is imposed administratively by OFAC and may apply even when a person or company did not know it was violating sanctions. A criminal penalty generally involves willful violations, is investigated and prosecuted by the U.S. Department of Justice, and may result in larger fines or imprisonment. The applicable penalties depend on the sanctions law involved.

An OFAC settlement is an agreement resolving potential civil liability for apparent sanctions violations. The person or company may agree to pay a settlement amount and adopt compliance commitments. A settlement generally closes OFAC’s civil enforcement matter but does not necessarily constitute a final agency finding that a violation occurred.

A Voluntary Self-Disclosure (VSD) occurs when a company or individual reports an apparent sanctions violation before, or at approximately the same time as, OFAC or another U.S. government agency discovers it. A qualifying VSD can reduce the base amount of a proposed civil penalty by 50%, although the final settlement amount depends on all relevant enforcement factors.

OFAC first calculates a base penalty using its Economic Sanctions Enforcement Guidelines. The calculation considers the transaction value or statutory maximum, whether the case is egregious, and whether the apparent violation was voluntarily self-disclosed. OFAC then applies its General Factors, including willfulness, management involvement, harm to sanctions objectives, compliance controls, cooperation, corrective action, enforcement history, and the subject’s size and financial condition.

The largest OFAC civil penalties include Binance at $968.6 million, BNP Paribas at $963.6 million, Standard Chartered Bank at $657 million, ING Bank at $619 million, and three UniCredit Group banks totaling $611 million. These amounts represent OFAC settlements and may form part of broader resolutions involving other U.S. authorities.

Yes. OFAC can impose civil penalties on individuals who violate U.S. sanctions regulations, not only on companies or financial institutions. The penalty depends on the applicable sanctions law and the circumstances of the violation.

Yes. OFAC can penalize non-U.S. companies when their conduct falls within U.S. sanctions jurisdiction, such as processing transactions through the U.S. financial system, causing U.S. persons to violate sanctions, evading sanctions restrictions, or violating rules that expressly apply to foreign entities.

The tracker covers sanctions programs cited in OFAC enforcement documents from 2003 to the present. These include country-based programs involving Iran, Cuba, Russia, North Korea, Syria, and Sudan, as well as targeted programs concerning terrorism, cyber activity, narcotics trafficking, weapons proliferation, and human rights abuses.