SanctionsLookupOFAC Enforcement Actions in 2020
OFAC published 16 civil penalties and settlements in 2020, totaling $23.6 million, 98% less than the 2019 total of $1.3 billion (26 actions). The largest 2020 OFAC penalty was $7.8 million against Société Internationale de Télécommunications Aéronautiques SCRL. Amounts are OFAC civil penalties only, excluding related DOJ, Federal Reserve, and state resolutions.
- Total penalties$23.6Mvs 2019: $1.29B
- Total actions16vs 2019: 26
- Largest penalty$7.8Mvs 2019: $639M
2020 OFAC Penalties
2020 OFAC Enforcement by the Numbers
OFAC resolved all 16 enforcement actions in 2020 through settlements. The median penalty was $563,252. Enforcement was concentrated in the second half of the year, with 4 actions in the first half and 12 in the second, including 8 in the third quarter.
Iran-related sanctions were cited in 5 of the 16 actions, Cuba, Russia, and Sudan in 4 each, and terrorism in 3. Banking accounted for 3 actions. 15 actions targeted companies and 1 targeted individuals.
OFAC found that 7 of the 16 cases were egregious and 9 involving voluntary self-disclosure. 12 of the 16 parties were based in the United States; the exceptions were Eagle Shipping International (USA) LLC of Marshall Islands, Société Internationale de Télécommunications Aéronautiques SCRL of Switzerland, Essentra FZE Company Limited of United Arab Emirates, and The National Commercial Bank of Saudi Arabia.
By total penalties, 2020 ranks 12th of the 18 years in this database, and 15th by number of actions. OFAC's calculated base penalties for 2020 totaled $164.9 million; the parties ultimately paid $23.6 million, an aggregate 86% reduction.