OFAC Enforcement Actions in 2024
OFAC published 12 civil penalties and settlements in 2024, totaling $48.8 million, 97% less than the 2023 total of $1.5 billion (17 actions). The largest 2024 OFAC penalty was $20 million against SCG Plastics Co., Ltd. Amounts are OFAC civil penalties only, excluding related DOJ, Federal Reserve, and state resolutions.
- Total penalties$48.8Mvs 2023: $1.54B
- Total actions12vs 2023: 17
- Largest penalty$20Mvs 2023: $969M
2024 OFAC Penalties
2024 OFAC Enforcement by the Numbers
OFAC resolved 11 of its 12 enforcement actions in 2024 through settlements and issued 1 penalty notice. The median penalty was $699,000. Enforcement was concentrated in the second half of the year, with 3 actions in the first half and 9 in the second, including 8 in the fourth quarter.
Iran-related sanctions were cited in 6 of the 12 actions, and Russia in 3. Banking accounted for 2 actions. 10 actions targeted companies and 2 targeted individuals.
OFAC found that 4 of the 12 cases were egregious, 1 egregious in part, and 4 involving voluntary self-disclosure. 7 of the 12 parties were based in the United States; the exceptions were EFG International AG of Switzerland, SCG Plastics Co., Ltd. of Thailand, Mondo TV, S.p.a. of Italy, Vietnam Beverage Company Limited of Vietnam, and Aiotec GmbH of Germany.
By total penalties, 2024 ranks 12th of the 22 years in this database, and 20th by number of actions. OFAC's calculated base penalties for 2024 totaled $673.1 million; the parties ultimately paid $48.8 million, an aggregate 93% reduction.