OFAC Enforcement Actions in 2006
OFAC published 35 civil penalties and settlements in 2006, totaling $40.7 million, more than 28 times the 2005 total of $1.4 million (92 actions). The largest 2006 OFAC penalty was $40 million against ABN AMRO Bank, N.V. Amounts are OFAC civil penalties only, excluding related DOJ, Federal Reserve, and state resolutions.
- Total penalties$40.7Mvs 2005: $1.4M
- Total actions35vs 2005: 92
- Largest penalty$40Mvs 2005: $112K
2006 OFAC Penalties
2006 OFAC Enforcement by the Numbers
OFAC resolved 22 of its 35 enforcement actions in 2006 through settlements and issued 7 penalty notices. The median penalty was $3,879. Enforcement was concentrated in the second half of the year, with 15 actions in the first half and 20 in the second, including 12 in the third quarter.
Cuba-related sanctions were cited in 19 of the 35 actions, Iran in 10, and Sudan in 3. Banking accounted for 4 actions. 21 actions targeted companies and 14 targeted individuals.
By total penalties, 2006 ranks 1st of the 4 years in this database, and 4th by number of actions.