SanctionsLookupOFAC Enforcement Actions in 2010
OFAC published 27 civil penalties and settlements in 2010, totaling $200.7 million, 74% less than the 2009 total of $772.4 million (27 actions). The largest 2010 OFAC penalty was $176 million against Barclays Bank PLC. Amounts are OFAC civil penalties only, excluding related DOJ, Federal Reserve, and state resolutions.
- Total penalties$201Mvs 2009: $772M
- Total actions27vs 2009: 27
- Largest penalty$176Mvs 2009: $536M
2010 OFAC Penalties
2010 OFAC Enforcement by the Numbers
OFAC resolved 21 of its 27 enforcement actions in 2010 through settlements and issued 5 penalty notices. The median penalty was $81,961. Enforcement was concentrated in the second half of the year, with 9 actions in the first half and 18 in the second, including 9 in the third quarter and 9 in the fourth.
Sudan-related sanctions were cited in 12 of the 27 actions, Iran in 7, and Cuba in 5. Banking accounted for 6 actions, and aviation accounted for 4 actions, machinery & equipment accounted for 3 actions. 24 actions targeted companies and 3 targeted individuals.
By total penalties, 2010 ranks 2nd of the 8 years in this database, and 8th by number of actions. For the 15 cases where OFAC published a base penalty, OFAC's calculated base penalties totaled $75.9 million; those parties ultimately paid $8 million, an aggregate 89% reduction.