SanctionsLookupOFAC Enforcement Actions in 2025
OFAC published 14 civil penalties and settlements in 2025, totaling $265.7 million, more than five times the 2024 total of $48.8 million (12 actions). The largest 2025 OFAC penalty was $216 million against GVA Capital Ltd. Amounts are OFAC civil penalties only, excluding related DOJ, Federal Reserve, and state resolutions.
- Total penalties$266Mvs 2024: $48.8M
- Total actions14vs 2024: 12
- Largest penalty$216Mvs 2024: $20M
2025 OFAC Penalties
2025 OFAC Enforcement by the Numbers
OFAC resolved 11 of its 14 enforcement actions in 2025 through settlements and issued 3 penalty notices. The median penalty was $2.4 million. Enforcement was concentrated in the second half of the year, with 4 actions in the first half and 10 in the second, including 5 in the third quarter and 5 in the fourth.
Russia-related sanctions were cited in 8 of the 14 actions, Iran in 6, and Cuba and Venezuela in 3 each. Crypto, logistics, private equity, and real estate each accounted for 2 actions. 12 actions targeted companies and 2 targeted individuals.
OFAC found that 7 of the 14 cases were egregious, 2 egregious in part, and 4 involving voluntary self-disclosure. 13 of the 14 parties were based in the United States; the exception was ShapeShift AG of Switzerland.
By total penalties, 2025 ranks 7th of the 23 years in this database, and 20th by number of actions. The 4 voluntarily disclosed cases settled for an average of $4.4 million; the 10 non-disclosed cases averaged $24.8 million, driven by GVA Capital. OFAC's calculated base penalties for 2025 totaled $397.1 million; the parties ultimately paid $265.7 million, an aggregate 33% reduction.