SanctionsLookupOFAC Enforcement Actions in 2019
OFAC published 26 civil penalties and settlements in 2019, totaling $1.3 billion, more than 18 times the 2018 total of $71.5 million (8 actions). The largest 2019 OFAC penalty was $639 million against Standard Chartered Bank. Amounts are OFAC civil penalties only, excluding related DOJ, Federal Reserve, and state resolutions.
- Total penalties$1.29Bvs 2018: $71.5M
- Total actions26vs 2018: 8
- Largest penalty$639Mvs 2018: $54M
2019 OFAC Penalties
2019 OFAC Enforcement by the Numbers
OFAC resolved 25 of its 26 enforcement actions in 2019 through settlements and issued 1 penalty notice. The median penalty was $486,581. Enforcement was concentrated in the first half of the year, with 18 actions in the first half and 8 in the second, including 13 in the second quarter.
Cuba-related sanctions were cited in 13 of the 26 actions, Iran in 9, Sudan in 6, and Burma and Syria in 4 each. Banking accounted for 6 actions, and machinery & equipment accounted for 4 actions, insurance and travel for 3 each. All 26 actions targeted companies.
OFAC found that 16 of the 26 cases involved voluntary self-disclosure. 16 of the 26 parties were based in the United States; the exceptions were AppliChem GmbH of Germany, Standard Chartered Bank of United Kingdom, Standard Chartered Bank of United Kingdom, Acteon Group Ltd. and 2H Offshore Engineering Ltd. of United Kingdom, Acteon Group Ltd. of United Kingdom, UniCredit Bank AG of Germany, UniCredit Bank Austria AG of Austria, UniCredit S.p.A. of Italy, British Arab Commercial Bank plc of United Kingdom, and Chubb Limited (as Successor Legal Entity of the Former ACE Limited) of Switzerland.
By total penalties, 2019 ranks 1st of the 17 years in this database, and 10th by number of actions. The 16 voluntarily disclosed cases settled for an average of $2.1 million; the 10 non-disclosed cases averaged $125.6 million, driven by Standard Chartered Bank. OFAC's calculated base penalties for 2019 totaled $4.6 billion; the parties ultimately paid $1.3 billion, an aggregate 72% reduction.