SanctionsLookupOFAC Enforcement Actions in 2012
OFAC published 16 civil penalties and settlements in 2012, totaling $1.1 billion, more than twelve times the 2011 total of $91.7 million (21 actions). The largest 2012 OFAC penalty was $619 million against ING Bank N.V. Amounts are OFAC civil penalties only, excluding related DOJ, Federal Reserve, and state resolutions.
- Total penalties$1.14Bvs 2011: $91.7M
- Total actions16vs 2011: 21
- Largest penalty$619Mvs 2011: $88.3M
2012 OFAC Penalties
2012 OFAC Enforcement by the Numbers
OFAC resolved 14 of its 16 enforcement actions in 2012 through settlements and issued 2 penalty notices. The median penalty was $426,000.
Iran-related sanctions were cited in 11 of the 16 actions, Sudan in 6, Burma and Cuba in 4 each, and Libya in 3. Banking accounted for 5 actions. All 16 actions targeted companies.
OFAC found that 5 of the 16 cases were egregious, 3 egregious in part, and 4 involving voluntary self-disclosure.
By total penalties, 2012 ranks 1st of the 10 years in this database, and 10th by number of actions. For the 12 cases where OFAC published a base penalty, OFAC's calculated base penalties totaled $2 billion; those parties ultimately paid $1.1 billion, an aggregate 45% reduction.