SanctionsLookupOFAC Enforcement Actions in 2021
OFAC published 20 civil penalties and settlements in 2021, totaling $20.9 million, 11% less than the 2020 total of $23.6 million (16 actions). The largest 2021 OFAC penalty was $8.6 million against Union de Banques Arabes et Françaises. Amounts are OFAC civil penalties only, excluding related DOJ, Federal Reserve, and state resolutions.
- Total penalties$20.9Mvs 2020: $23.6M
- Total actions20vs 2020: 16
- Largest penalty$8.6Mvs 2020: $7.8M
2021 OFAC Penalties
2021 OFAC Enforcement by the Numbers
OFAC resolved 19 of its 20 enforcement actions in 2021 through settlements. The median penalty was $435,003. Enforcement was concentrated in the second half of the year, with 8 actions in the first half and 12 in the second, including 8 in the third quarter.
Iran-related sanctions were cited in 11 of the 20 actions, Sudan and Syria in 5 each, and Kingpin, Northkorea, and Russia in 3 each. Banking accounted for 6 actions, and machinery & equipment accounted for 4 actions. 19 actions targeted companies and 1 targeted individuals.
12 of the 20 parties were based in the United States; the exceptions were Union de Banques Arabes et Françaises of France, PT Bukit Muria Jaya of Indonesia, Nordgas S.r.l. of Italy, SAP SE of Germany, Alfa Laval Middle East Ltd. of United Arab Emirates, Bank of China (UK) Limited of United Kingdom, First Bank SA and JC Flowers & Co. of Romania, and Mashreqbank psc of United Arab Emirates.
By total penalties, 2021 ranks 14th of the 19 years in this database, and 13th by number of actions. For the 19 cases where OFAC published a base penalty, OFAC's calculated base penalties totaled $43.4 million; those parties ultimately paid $20.9 million, an aggregate 52% reduction.