SanctionsLookupOFAC Enforcement Actions in 2023
OFAC published 17 civil penalties and settlements in 2023, totaling $1.5 billion, more than 36 times the 2022 total of $42.7 million (16 actions). The largest 2023 OFAC penalty was $968.6 million against Binance Holdings, Ltd. Amounts are OFAC civil penalties only, excluding related DOJ, Federal Reserve, and state resolutions.
- Total penalties$1.54Bvs 2022: $42.7M
- Total actions17vs 2022: 16
- Largest penalty$969Mvs 2022: $24.3M
2023 OFAC Penalties
2023 OFAC Enforcement by the Numbers
OFAC resolved all 17 enforcement actions in 2023 through settlements. The median penalty was $3 million. Enforcement was concentrated in the first half of the year, with 9 actions in the first half and 8 in the second, including 6 in the second quarter.
Iran-related sanctions were cited in 12 of the 17 actions, Russia in 7, Cuba and Syria in 5 each, and Northkorea in 3. Crypto accounted for 4 actions, and banking accounted for 3 actions. 16 actions targeted companies and 1 targeted individuals.
OFAC found that 7 of the 17 cases were egregious and 9 involving voluntary self-disclosure. 13 of the 17 parties were based in the United States; the exceptions were Godfrey Phillips India Limited of India, British American Tobacco p.l.c. of United Kingdom, Swedbank Latvia AS of Latvia, and Binance Holdings, Ltd. of Cayman Islands.
By total penalties, 2023 ranks 1st of the 21 years in this database, and 15th by number of actions. The 9 voluntarily disclosed cases settled for an average of $5.7 million; the 8 non-disclosed cases averaged $186.3 million, driven by Binance Holdings. OFAC's calculated base penalties for 2023 totaled $593.3 billion; the parties ultimately paid $1.5 billion, an aggregate 100% reduction.