SanctionsLookupOFAC Enforcement Actions in 2015
OFAC published 15 civil penalties and settlements in 2015, totaling $599.7 million, 49% less than the 2014 total of $1.2 billion (23 actions). The largest 2015 OFAC penalty was $329.6 million against Crédit Agricole Corporate and Investment Bank. Amounts are OFAC civil penalties only, excluding related DOJ, Federal Reserve, and state resolutions.
- Total penalties$600Mvs 2014: $1.17B
- Total actions15vs 2014: 23
- Largest penalty$330Mvs 2014: $964M
2015 OFAC Penalties
2015 OFAC Enforcement by the Numbers
OFAC resolved 14 of its 15 enforcement actions in 2015 through settlements and issued 1 penalty notice. The median penalty was $214,000. Enforcement was concentrated in the second half of the year, with 6 actions in the first half and 9 in the second, including 5 in the third quarter.
Iran-related sanctions were cited in 7 of the 15 actions, Cuba, Sudan, and WMD in 5 each, and terrorism in 3. Banking accounted for 5 actions. All 15 actions targeted companies.
OFAC found that 5 of the 15 cases involved voluntary self-disclosure.
By total penalties, 2015 ranks 4th of the 13 years in this database, and 13th by number of actions. The 5 voluntarily disclosed cases settled for an average of $1.6 million; the 10 non-disclosed cases averaged $59.2 million, driven by Crédit Agricole Corporate and Investment Bank. For the 14 cases where OFAC published a base penalty, OFAC's calculated base penalties totaled $2.1 billion; those parties ultimately paid $599.7 million, an aggregate 71% reduction.