OFAC published 23 civil penalties and settlements in 2014, totaling $1.2 billion, more than eight times the 2013 total of $137.1 million (27 actions). The largest 2014 OFAC penalty was $963.6 million against BNP Paribas SA. Amounts are OFAC civil penalties only, excluding related DOJ, Federal Reserve, and state resolutions.
OFAC resolved 22 of its 23 enforcement actions in 2014 through settlements and issued 1 penalty notice. The median penalty was $217,841. Enforcement was concentrated in the first half of the year, with 13 actions in the first half and 10 in the second, including 9 in the second quarter.
Iran-related sanctions were cited in 12 of the 23 actions, Cuba in 7, Sudan in 5, and Kingpin, Narcotics, and WMD in 3 each. Banking accounted for 5 actions, and hardware & electronics accounted for 3 actions. 22 actions targeted companies and 1 targeted individuals.
OFAC found that 8 of the 23 cases involved voluntary self-disclosure.
By total penalties, 2014 ranks 1st of the 12 years in this database, and 10th by number of actions. For the 22 cases where OFAC published a base penalty, OFAC's calculated base penalties totaled $26 billion; those parties ultimately paid $1.2 billion, an aggregate 96% reduction.
SanctionsLookup