SanctionsLookupOFAC Enforcement Actions in 2018
OFAC published 8 civil penalties and settlements in 2018, totaling $71.5 million, 40% less than the 2017 total of $120 million (17 actions). The largest 2018 OFAC penalty was $54 million against Société Générale S.A. Amounts are OFAC civil penalties only, excluding related DOJ, Federal Reserve, and state resolutions.
- Total penalties$71.5Mvs 2017: $120M
- Total actions8vs 2017: 17
- Largest penalty$54Mvs 2017: $101M
2018 OFAC Penalties
2018 OFAC Enforcement by the Numbers
OFAC resolved 7 of its 8 enforcement actions in 2018 through settlements. The median penalty was $2.8 million. Enforcement was concentrated in the second half of the year, with 1 actions in the first half and 7 in the second, including 6 in the fourth quarter.
Iran-related sanctions were cited in 4 of the 8 actions. Banking accounted for 3 actions. All 8 actions targeted companies.
5 of the 8 parties were based in the United States; the exceptions were Ericsson, Inc. and Ericsson AB of Sweden; United States, Société Générale S.A. of France, and Yantai Jereh Oilfield Services Group Co., Ltd. of China.
By total penalties, 2018 ranks 9th of the 16 years in this database, and 16th by number of actions. For the 6 cases where OFAC published a base penalty, OFAC's calculated base penalties totaled $124.8 million; those parties ultimately paid $70 million, an aggregate 44% reduction.