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.
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.
SanctionsLookup