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.
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.
SanctionsLookup