OFAC published 17 civil penalties and settlements in 2017, totaling $120 million, more than five times the 2016 total of $21.6 million (9 actions). The largest 2017 OFAC penalty was $100.9 million against Zhongxing Telecommunications Equipment Corporation. Amounts are OFAC civil penalties only, excluding related DOJ, Federal Reserve, and state resolutions.
OFAC resolved 15 of its 17 enforcement actions in 2017 through settlements and issued 1 penalty notice. The median penalty was $415,350. Enforcement was concentrated in the second half of the year, with 8 actions in the first half and 9 in the second, including 6 in the third quarter.
Iran-related sanctions were cited in 11 of the 17 actions, and Cuba in 6. Banking accounted for 3 actions. All 17 actions targeted companies.
By total penalties, 2017 ranks 7th of the 15 years in this database, and 12th by number of actions. For the 15 cases where OFAC published a base penalty, OFAC's calculated base penalties totaled $154 million; those parties ultimately paid $119 million, an aggregate 23% reduction.
SanctionsLookup