OFAC Enforcement Actions in 2014
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.
- Total penalties$1.17Bvs 2013: $137M
- Total actions23vs 2013: 27
- Largest penalty$964Mvs 2013: $91M
2014 OFAC Penalties
2014 OFAC Enforcement by the Numbers
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.