OFAC Enforcement Actions in 2013
OFAC published 27 civil penalties and settlements in 2013, totaling $137.1 million, 88% less than the 2012 total of $1.1 billion (16 actions). The largest 2013 OFAC penalty was $91 million against Weatherford International Ltd. Amounts are OFAC civil penalties only, excluding related DOJ, Federal Reserve, and state resolutions.
- Total penalties$137Mvs 2012: $1.14B
- Total actions27vs 2012: 16
- Largest penalty$91Mvs 2012: $619M
2013 OFAC Penalties
2013 OFAC Enforcement by the Numbers
OFAC resolved 25 of its 27 enforcement actions in 2013 through settlements and issued 2 penalty notices. The median penalty was $97,695. Enforcement was concentrated in the first half of the year, with 14 actions in the first half and 13 in the second, including 8 in the first quarter.
Iran-related sanctions were cited in 19 of the 27 actions, Cuba in 9, Sudan in 6, and WMD in 3. Banking accounted for 8 actions, and energy services, healthcare, and trading for 3 each. All 27 actions targeted companies.
OFAC found that 5 of the 27 cases involved voluntary self-disclosure.
By total penalties, 2013 ranks 4th of the 11 years in this database, and 9th by number of actions. OFAC's calculated base penalties for 2013 totaled $195 million; the parties ultimately paid $137.1 million, an aggregate 30% reduction.