SanctionsLookupOFAC Enforcement Actions in 2016
OFAC published 9 civil penalties and settlements in 2016, totaling $21.6 million, 96% less than the 2015 total of $599.7 million (15 actions). The largest 2016 OFAC penalty was $7.6 million against Alcon Laboratories, Inc., Alcon Pharmaceuticals Ltd., and Alcon Management, SA. Amounts are OFAC civil penalties only, excluding related DOJ, Federal Reserve, and state resolutions.
- Total penalties$21.6Mvs 2015: $600M
- Total actions9vs 2015: 15
- Largest penalty$7.6Mvs 2015: $330M
2016 OFAC Penalties
2016 OFAC Enforcement by the Numbers
OFAC resolved all 9 enforcement actions in 2016 through settlements. The median penalty was $614,250. Enforcement was concentrated in the first half of the year, with 5 actions in the first half and 4 in the second, including 4 in the first quarter.
Iran-related sanctions were cited in 5 of the 9 actions, and Cuba in 4. Energy services and healthcare each accounted for 3 actions. All 9 actions targeted companies.
OFAC found that 1 of the 9 cases were egregious, 1 egregious in part, and 2 involving voluntary self-disclosure. 6 of the 9 parties were based in the United States; the exceptions were Barclays Bank Plc of United Kingdom, CGG Services S.A. on behalf of CGG Services (U.S.) Inc. and Veritas Geoservices Ltd. S.A. of France, and Halliburton Atlantic Limited on behalf of itself and Halliburton Overseas Limited of Cayman Islands.
By total penalties, 2016 ranks 9th of the 14 years in this database, and 14th by number of actions. The 2 voluntarily disclosed cases settled for an average of $206,199; the 7 non-disclosed cases averaged $3 million. OFAC's calculated base penalties for 2016 totaled $44.4 million; the parties ultimately paid $21.6 million, an aggregate 51% reduction.