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

NameProgramView
1212/31/2024
SkyGeek Logistics, Inc.Aviation
russia
$22,172›
1112/18/2024
U.S. Person-1Individual
magnitsky
$45,179›
1012/18/2024
Córdoba Music Group LLCHardware & Electronics
iran
$41,591›
912/13/2024
C.H. Robinson International Inc.Logistics
cubairan
$257,690›
812/3/2024
Aiotec GmbHTrading
iran
$14,550,000›
711/19/2024
U.S. Person-1Individual
iran
$1,104,408›
611/14/2024
American Life Insurance CompanyInsurance
iran
$178,421›
510/17/2024
Vietnam Beverage Company LimitedFood & Beverage
northkorea
$860,000›
47/26/2024
State Street Bank and Trust Company on behalf of itself and its subsidiary, Charles River Systems, Inc.Banking
russia
$7,452,501›
36/26/2024
Mondo TV, S.p.a.Media
northkorea
$538,000›
24/19/2024
SCG Plastics Co., Ltd.Materials & Components
iran
$20,000,000›
13/14/2024
EFG International AGBanking
cubakingpin+1
$3,740,442›

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.

OFAC Enforcement Actions by Year