SanctionsLookupOFAC Enforcement Actions in 2009
OFAC published 27 civil penalties and settlements in 2009, totaling $772.4 million, more than 219 times the 2008 total of $3.5 million (105 actions). The largest 2009 OFAC penalty was $536 million against Credit Suisse AG. Amounts are OFAC civil penalties only, excluding related DOJ, Federal Reserve, and state resolutions.
- Total penalties$772Mvs 2008: $3.5M
- Total actions27vs 2008: 105
- Largest penalty$536Mvs 2008: $1.2M
2009 OFAC Penalties
2009 OFAC Enforcement by the Numbers
OFAC resolved 21 of its 27 enforcement actions in 2009 through settlements and issued 6 penalty notices. The median penalty was $33,000. Enforcement was concentrated in the first half of the year, with 16 actions in the first half and 11 in the second, including 9 in the second quarter.
Cuba-related sanctions were cited in 12 of the 27 actions, Sudan in 9, and Iran in 8. Banking, machinery & equipment, and payments each accounted for 3 actions. 22 actions targeted companies and 5 targeted individuals.
By total penalties, 2009 ranks 1st of the 7 years in this database, and 7th by number of actions. For the 1 cases where OFAC published a base penalty, OFAC's calculated base penalties totaled $1.7 billion; those parties ultimately paid $536 million, an aggregate 69% reduction.