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OFAC enforcement action finder

Every civil enforcement action OFAC has published since 2015, 179 in all through Oct 27, 2026, read from the enforcement release and coded for what the compliance program missed: third-party payments, ownership checks, a filter that skipped a field, an alert that was cleared. Filter by year, industry, program, failure, whether the case involved paying or being paid by a sanctioned party, type of action, self-disclosure and egregiousness; search the entity names and summaries. Each card links to OFAC's own release.

Basis OFAC Civil Penalties and Enforcement Information pages for 2015 to 2025 and the current-year page, and the enforcement release PDF for each action, all read Nov. 1, 2026; penalty amounts, violation counts and the self-disclosure and egregiousness determinations are as stated in each releasePrivacy runs in your browser; nothing you enter is sent or stored

Find an enforcement action

Matches words in the entity name, summary and programs.
Most actions carry two to four tags.
On: the respondent paid, or was paid by, a blocked party, supplier, distributor, customer or counterparty. Off: all actions, including bank wire processing, platform access and personal conduct.
actions in this filter
total announced penalties
median penalty (actions with a penalty)
voluntarily self-disclosed

The what failed tags, the industry and the AP or vendor relevance flag are this site’s reading of each enforcement release, applied with the vocabulary explained below. They are an index, not OFAC’s own classification; the release controls, and every card links to it.

Oct 27, 2026Settlement$1,529,685

Extreme Networks, Inc. (Extreme Networks Rus LLC)

Manufacturing and trade (networking equipment and cloud services) · Ukraine/Russia program · 9 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: yes

50 Percent Rule missedCustomer or counterparty due diligenceAlerts cleared wronglyThird-party or vendor payments

Extreme's Russian subsidiary bought customer contracts in 2018 that named MMZA, a missile maker majority-owned by SDN Almaz-Antey, and over three years fulfilled nine purchase orders for it under the name of another company, DEMZ, even though seven POs carried MMZA email addresses or its Moscow address and the distributor twice sent MMZA's website when asked for the end user. The US compliance team screened every order under a Russia review policy but never recognized the 50 percent ownership.

“seven of which included MMZA email addresses or identified MMZA’s office address in Moscow as the ultimate destination”
Mitigating and aggravating factors
Mitigating
  • no OFAC enforcement action in prior five years
  • enhanced screening for majority-owned and military-affiliated entities, expanded end-user diligence, more staff, training, M&A diligence covering target customers
Aggravating
  • reckless failure to do due diligence or heed warning signs that MMZA was the real end user
  • actual knowledge of the orders and reason to know MMZA was the end user
  • benefited the sole supplier of S-300 and S-400 missile systems

Note: coordinated with a parallel DOJ resolution.

Source: OFAC enforcement release (PDF), United States (Russian subsidiary); read Nov. 1, 2026.

Oct 13, 2026Settlement$11,662,930

Bank of America, N.A.

Banking · Ukraine/Russia and Belarus and Iran and Burma and Somalia and Narcotics and SDN/counterterrorism programs · 475 apparent violations · not an AP or vendor case · self-disclosed: partial · egregious: no

Screening skipped data fieldsAlerts cleared wronglyLegacy or unintegrated systemName matching false negative

A vendor-supplied routing directory kept steering cross-border payments through 35 blocked banks for three years after Russia sanctions, with alerts lost to delayed filter updates, analyst error and an 'alert suppression rule' that auto-released repeats of past false positives; the bank processed $14.3 million through blocked banks and did only a narrow lookback until a 2025 subpoena. Exact name and date-of-birth matches were also ranked low priority by a design flaw, vendor and system failures left the watchlist stale, and staff moved $189,869 from blocked-signer accounts into a fresh account.

“the payments were released automatically due to an “alert suppression rule,””
Mitigating and aggravating factors
Mitigating
  • tolling agreement on the Kingpin-related violations; no net reduction warranted
Aggravating
  • reckless delay in screening fixes, watchlist updates, alert prioritization and staff training
  • over $14 million through blocked banks contrary to Russia program objectives
  • very large sophisticated institution
  • multiple prior cautionary letters for substantially similar conduct

Note: largely not self-disclosed; no reduction from base penalty, no mitigation for remediation or cooperation.

Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

Oct 9, 2026Settlement$175,015

Pegasus Worldwide Logistics

Logistics and freight (freight forwarder) · Narcotics program · violation count not stated · AP or vendor relevant · self-disclosed: no · egregious: no

Screening skipped data fieldsName matching false negativeThird-party or vendor paymentsNo compliance program

A twelve-person freight forwarder arranged import of a $5,950 packet-filling machine from Youli Technology, a Chinese pill press supplier designated under fentanyl sanctions, emailing the exact address listed on the SDN entry. Youli had changed its name after designation, Pegasus screened only the new name just before departure and ignored the unchanged phone and email identifiers, then paid duties and fees even after CBP detained the machine citing OFAC.

“Screening the other identifiers, including through a basic internet search, would have yielded a positive match for Youli”
Mitigating and aggravating factors
Mitigating
  • no OFAC enforcement action in prior five years
  • small company and low-value transactions
  • extensive remediation with an outside sanctions consultant and extended reporting to OFAC
Aggravating
  • reckless failure to screen identifiers in its possession and to investigate after the CBP detention
  • aware it was dealing with Youli, which it had reason to know was the designated party
  • helped an SDN keep exporting to the US, and a deficient subpoena response
  • freight forwarding role warranted heightened attention

Note: also an initial failure to fully respond to an OFAC subpoena.

Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

Sep 10, 2026Settlement$1,427,230

An Individual (co-founder of an Iranian software company)

Other: individual · Iran program · 39 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: yes

Facilitation

A US permanent resident who co-founded a leading Iranian software company joined 19 virtual management meetings with its executives, received $713,615 of Iranian dividends into US bank accounts through banks in Türkiye, the UAE and Singapore, and bought four properties in Iran with the proceeds. The person had written about Iran sanctions in 2000 and gave an incomplete first subpoena response.

“provided management consulting and advisory services to one of Iran’s leading software solutions companies, received Iranian-origin dividends to their U.S. bank accounts”
Mitigating and aggravating factors
Mitigating

None stated in the release.

Aggravating
  • willful multi-year pattern knowing Iran was sanctioned

The release lists further factors; see the source.

Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

Aug 12, 2026Settlement$60,764

Rice Lake Weighing Systems, Inc. (for Dini Argeo S.r.l.)

Manufacturing and trade (weighing equipment) · Iran program · 8 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

Third-party or vendor paymentsCustomer or counterparty due diligenceNo compliance program

After General License H was revoked in 2018, Rice Lake sent its Italian subsidiary Dini a terse English email quoting the ITSR, and Dini stopped direct Iran sales but kept filling eight orders worth $121,527 for a UAE distributor it knew re-exported to its old Iranian customer Pandtec, whose staff kept emailing with Iran in their signatures. A tip in 2021 led to an investigation and self-disclosure.

“Rice Lake did not include any further explanation or translation”
Mitigating and aggravating factors
Mitigating
  • no OFAC enforcement action in prior five years
  • very small share of sales
  • prompt investigation with outside counsel and compliance improvements including subsidiary training
Aggravating
  • Dini recklessly treated indirect sales as permitted and Rice Lake gave no practical guidance or monitoring
  • Dini knew or had reason to know goods were going to Iran
  • commercial weighing products furthered Iran's economy

Source: OFAC enforcement release (PDF), United States (Italian subsidiary); read Nov. 1, 2026.

Jun 1, 2026Settlement$1,050,000

FTI Consulting, Inc.

Other: consulting and advisory · Ukraine/Russia program · 6 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

FacilitationAlerts cleared wronglyCustomer or counterparty due diligence

FTI structured an expert consulting engagement for VTB, an SSI List bank subject to Directive 1's 14-day debt limit, so that it invoiced the law firm rather than VTB and got paid only when VTB paid the firm, then kept working and issuing invoices while payments went unpaid for months. OFAC treated the indirect invoices as prohibited new debt to VTB and stressed that what cannot be done directly cannot be done indirectly.

“it is prohibited to do indirectly what one cannot do directly”
Mitigating and aggravating factors
Mitigating
  • tolling and comprehensive cooperation including privilege waiver
  • very small relative to FTI's payment volumes

The release lists further factors; see the source.

Aggravating
  • senior managers recklessly missed warning signs after designing the arrangement around the known VTB risk
  • extended impermissibly long credit to VTB and the indirect structure obscured activity from intermediary screening
  • large sophisticated global firm

Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

May 18, 2026Settlement$275,000,000

Adani Enterprises Limited

Other: diversified conglomerate, LPG trading · Iran program · 32 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: yes

Third-party or vendor paymentsCustomer or counterparty due diligenceScreening skipped data fields

Adani bought 35 cargoes of discounted LPG from a Dubai trader that claimed Omani and Iraqi origin, paying $192 million in USD through US banks for 32 of them, while third parties warned four times that the cargoes were Iranian and the vessels showed AIS manipulation, illogical port calls and frequent flag changes. Its KYC and SDN checks on the supplier, vessels and operators all came back clean because none were listed, but the program had no controls for origin or vessel behavior risk.

“Red flags should have put AEL on notice that the LPG actually originated from Iran”
Mitigating and aggravating factors
Mitigating
  • no penalty notice or Finding of Violation in prior five years
  • LPG was under 1.5 percent of consolidated revenue
  • expedited independent internal investigation and large data productions
  • ceased LPG imports into India and enhanced policy and controls
Aggravating
  • reckless disregard of third-party warnings and the commercial implausibility of origin and pricing, no vessel behavior diligence
  • substantial revenue to Iran's energy sector
  • large sophisticated company with energy operations

Source: OFAC enforcement release (PDF), India; read Nov. 1, 2026.

Mar 17, 2026Settlement$1,110,661

TradeStation Securities, Inc.

Fintech and digital assets (online brokerage) · Iran and Syria and Crimea and Ukraine/Russia programs · 481 apparent violations · not an AP or vendor case · self-disclosed: yes · egregious: no

Geolocation or IP data ignoredLegacy or unintegrated system

A 2018 mobile app rewrite made TradeStation's second-tier geoblocking read the IP of its own US server instead of the user, and in June 2021 an employee disabled the first-tier firewall for a cloud update and never re-enabled it, so users in Iran, Syria and Crimea traded 481 times over a year. Its automated geoblock test tool had been discontinued in November 2021 without replacement, despite an OFAC cautionary letter earlier that year about geoblocking defects.

“inadvertently failed to reenable the first-tier geo-blocking control after disabling it to install a software update”
Mitigating and aggravating factors
Mitigating

    The release lists further factors; see the source.

    Aggravating
    • left deficiencies unaddressed for a year despite a 2021 cautionary letter, discontinued testing and ignored eight months of missing daily alerts
    • 481 trades for persons in sanctioned jurisdictions
    • sophisticated regulated technology firm

    Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

    Feb 25, 2026Settlement$3,777,000

    An Individual (executive and board member of Syrian real estate companies)

    Other: individual · Syria program · 20 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: yes

    Facilitation

    A naturalized US citizen living abroad served as executive and board member of four Syrian luxury real estate developers worth up to $1.5 billion, approving expenses and budgets, signing financial statements and managing staff from 2018 to 2021 while Syria sanctions were in force. The conduct stopped only after an OFAC subpoena.

    “U.S. Person-1 only stopped after receiving an administrative subpoena from OFAC”
    Mitigating and aggravating factors
    Mitigating

      The release lists further factors; see the source.

      Aggravating
      • reckless multi-year pattern that stopped only after a subpoena
      • actual knowledge of managing Syrian firms
      • developed Syria's luxury real estate sector under al-Assad
      • experienced real estate executive

      Source: OFAC enforcement release (PDF), United States (residing abroad); read Nov. 1, 2026.

      Feb 12, 2026Settlement$1,720,000

      IMG Academy, LLC

      Other: boarding school and athletic training · Narcotics program · 89 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

      No screening performedCustomer or counterparty due diligenceThird-party or vendor paymentsNo compliance program

      For five years IMG Academy signed annual tuition agreements with and invoiced by name two individuals designated under the Kingpin Act for financing a Mexican cartel, collecting about $100,000 a year per student through third-party wires from Mexico and cards on file. It never screened counterparties, though the full names on the agreements matched the SDN List exactly.

      “Minimal due diligence at any point throughout this process would have revealed that these customers were sanctioned”
      Mitigating and aggravating factors
      Mitigating
      • no penalty notice or Finding of Violation in prior five years
      • new Chief Legal Officer after a 2023 ownership change ran a lookback and built a risk-based program
      • timely cooperation and tolling
      Aggravating
      • reckless disregard by never screening counterparties whose names matched the SDN List
      • actual knowledge of the agreements and invoices with the SDNs by name
      • gave cartel financiers access to US commerce and the financial system

      Note: disclosure made after OFAC had opened an investigation; settlement equals base penalty.

      Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

      Dec 16, 2025Settlement$3,103,360

      Exodus Movement, Inc.

      Fintech and digital assets (digital asset wallet software) · Iran program · 254 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: mixed

      Geolocation or IP data ignoredNo compliance programFacilitation

      Exodus customer support helped self-identified Iranian users 254 times to keep using its wallet and partner exchanges, and on 12 occasions, after acknowledging that an exchange blocked Iran to comply with US sanctions, recommended VPNs to get around it. Its terms of use barred embargoed countries but staff were not trained and no technical control enforced them.

      “Exodus staff recommended that these users obscure their location in Iran using Virtual Private Networks (VPNs)”
      Mitigating and aggravating factors
      Mitigating

        The release lists further factors; see the source.

        Aggravating
        • 12 willful VPN recommendations to circumvent exchange controls
        • reckless support to Iranian users despite terms of use and CEO awareness
        • actual knowledge since users identified their location
        • undermined partners' blocking controls

        Note: 12 of 254 violations egregious.

        Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

        Dec 9, 2025Settlement$1,092,000

        An Individual (attorney serving as trust fiduciary)

        Other: individual, professional services gatekeeper · Ukraine/Russia program · 122 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

        50 Percent Rule missedFacilitationThird-party or vendor payments

        An attorney and former government official served as fiduciary of a US trust funded almost entirely by a Russian oligarch and, after the oligarch's 2018 designation, kept authorizing asset transfers, service provider payments and agreements for four years on the strength of outside counsel's opinion that the trust was not blocked. OFAC said the fiduciary should have known the oligarch's family proxy still controlled decisions, so the oligarch retained a property interest.

        “the Proxy’s continued involvement following SDN-1’s designation allowed SDN-1 to retain control over decisions made related to the Trust”
        Mitigating and aggravating factors
        Mitigating
        • no penalty notice or Finding of Violation in prior five years
        • substantial cooperation with subpoenas and tolling
        Aggravating
        • relied on legal advice but should have known the proxy's role meant the SDN retained control
        • let a designated oligarch use the US financial system and grow trust assets, lending legitimacy to the trust

        Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

        Dec 4, 2025Penalty notice$7,139,305

        Gracetown, Inc.

        Other: property management · Ukraine/Russia program · 25 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: yes

        50 Percent Rule missedThird-party or vendor paymentsFacilitation

        A New York property manager for Oleg Deripaska's luxury homes kept receiving 24 monthly settlement payments due to Baufinanz, a BVI company Deripaska owned, for two years after OFAC mailed it a Notification of Blocking, booking them as loans to cover property expenses. It reported the $103,750 blocked debt 45 months late.

        “Gracetown nevertheless received 24 more payments on behalf of its affiliate company, which it knew was owned by Deripaska”
        Mitigating and aggravating factors
        Mitigating

        None stated in the release.

        Aggravating
        • willful or reckless receipt of payments after actual notice from OFAC
        • property manager and new owner knowingly continued the arrangement
        • benefited Deripaska by collecting a debt for Baufinanz
        • deficient remedial response

        Note: 24 URSR violations plus a reporting violation under 31 CFR 501.603; disclosure came after the government already knew.

        Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

        Dec 2, 2025Settlement$11,485,352

        IPI Partners, LLC

        Other: private equity, data centers · Ukraine/Russia program · 51 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

        50 Percent Rule missedCustomer or counterparty due diligenceThird-party or vendor payments

        IPI took $50 million in fund commitments from Definition Services, a BVI vehicle of a Kerimov family trust, after its senior member met Kerimov and his nephew-representative in person, then kept issuing capital calls, distributions and management fee payments for four years after Kerimov's designation. Outside counsel said no blocking was needed because Kerimov did not formally own 50 percent, but IPI had not told counsel about the in-person dealings and relied on an attestation it had reason to know was false.

        “outside counsel concluded that IPI was under no obligation to block the account because Kerimov did not formally own 50% or more of Definition”
        Mitigating and aggravating factors
        Mitigating
        • no penalty notice or Finding of Violation in prior five years
        • cooperation improved after new counsel and a privilege waiver, but initial delay limited credit
        Aggravating
        • senior executives knew Kerimov was the source of funds and dealt with his representative after designation
        • let a designated oligarch grow wealth through a US fund
        • sophisticated private equity firm managing billions

        Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

        Nov 24, 2025Penalty notice$4,677,552

        An Individual (acting through King Holdings LLC)

        Other: real estate investment · Ukraine/Russia program · 3 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: yes

        Facilitation

        An investor bought a foreclosed Atlanta home owned in her own name by a designated Russian oligarch's relative, and after OFAC told the buyer the property remained blocked, mortgaged it for $872,338, renovated it and sold it to an unwitting buyer for $1.4 million, omitting the pending sale from a certified subpoena response and closing days after certifying compliance with a cease-and-desist order.

        “willfully dealt in residential real property owned by a blocked individual, including by mortgaging, renovating, and selling the property”
        Mitigating and aggravating factors
        Mitigating

        None stated in the release.

        Aggravating
        • willful dealings for nearly a year after actual notice and a false subpoena certification
        • aware of the conduct at all times
        • exposed third parties to harm and damaged sanctions integrity
        • failed to cooperate

        Note: two RuHSR violations plus one subpoena violation under 31 CFR 501.602; statutory maximum imposed.

        Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

        Sep 22, 2025Settlement$750,000

        ShapeShift AG

        Fintech and digital assets (digital asset exchange) · Cuba and Iran and Sudan and Syria programs · 17,183 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: no

        No compliance programGeolocation or IP data ignored

        ShapeShift, Swiss-incorporated but run from Denver, had no sanctions program and exchanged $12.6 million of digital assets in 17,183 transactions with users in Cuba, Iran, Sudan and Syria, although IP addresses were the one location indicator it held. It adopted screening and IP blocking only after an OFAC subpoena.

        “the IP addresses were the “only available indicator” that ShapeShift collected regarding a party’s location”
        Mitigating and aggravating factors
        Mitigating
        • relatively small and now defunct with constrained finances
        • no penalty notice or Finding of Violation in prior five years
        • timely cooperation and tolling
        • small share of volume
        • remedial program after discovery
        Aggravating
        • no internal controls to keep sanctioned-jurisdiction users off the platform
        • had reason to know from IP data
        • economic benefit to persons in several sanctioned jurisdictions

        Note: defunct company with limited assets; year table lists 39 violations but release states 17,183 instances.

        Source: OFAC enforcement release (PDF), Switzerland (operated from Denver); read Nov. 1, 2026.

        Sep 3, 2025Settlement$1,610,775

        Fracht FWO Inc.

        Logistics and freight (freight forwarding) · Venezuela and Iran and SDN/counterterrorism and WMD programs · 4 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: yes

        No screening performedThird-party or vendor payments50 Percent Rule missedCustomer or counterparty due diligence

        Under pressure to move car parts from Mexico to Argentina, Fracht's vice president of airfreight signed a charter through a broker naming EMTRASUR, a subsidiary of blocked Venezuelan airline CONVIASA, with a Venezuelan tail number and a Venezuela layover, without the sanctions screening or legal review its policies required. The aircraft turned out to be Mahan Air blocked property with an Iranian crew, and Fracht paid $995,000 including a late fee.

        “executed the contract without undertaking sanctions screening or internal legal review, contrary to Fracht’s compliance policies and procedures”
        Mitigating and aggravating factors
        Mitigating
        • no Finding of Violation or penalty notice in prior five years
        • terminated the contracting employee, legal review and sanctions due diligence for all contracts, vendor vetting with compliance approval, nine compliance staff, over $1 million a year on compliance
        Aggravating
        • two vice presidents recklessly bypassed compliance processes and ignored red flags
        • managers knew the contract and payments involved EMTRASUR
        • $935,000 direct benefit to a blocked entity and the Maduro regime using a terrorism-blocked aircraft
        • large sophisticated forwarder

        Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

        Jul 15, 2025Settlement$11,832,136

        Interactive Brokers LLC

        Fintech and digital assets (online broker-dealer) · Iran and Cuba and Syria and Crimea and Ukraine/Russia and NS-CMIC and Magnitsky and Venezuela programs · 12,367 apparent violations · not an AP or vendor case · self-disclosed: yes · egregious: no

        Geolocation or IP data ignoredScreening skipped data fieldsAlerts cleared wronglyLegacy or unintegrated system50 Percent Rule missed

        A technical bug in IP geoblocking let over 200 accountholders trade from Iran, Cuba, Syria and Crimea for five years, Crimea and then Sevastopol were missing from the blocking list, and IB also sent 259 customer transfers to blocked Russian banks, traded NS-CMIC securities and dealt with blocked persons. The 12,367 violations came from a self-initiated review and IB spent over $10 million on remediation.

        “certain deficiencies in IB’s IP geo-blocking controls (including a technical bug) allowed access by a limited number of customers located in Iran, Cuba, and Syria”
        Mitigating and aggravating factors
        Mitigating
        • no penalty notice or Finding of Violation in prior five years
        • under 0.0001 percent of volume with limited benefit
        • over $10 million in remediation including more frequent screening, second-level review, proprietary screening logic, enhanced IP geoblocking
        Aggravating
        • no willfulness but failed due caution across the business for at least eight years with reason to know
        • access to the US financial system for persons in sanctioned countries and blocked Russian banks
        • highly sophisticated regulated global firm

        Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

        Jul 8, 2025Settlement$1,454,145

        Harman International Industries, Inc. (Harman Professional, Inc.)

        Manufacturing and trade (audio electronics) · Iran program · 11 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: yes

        Third-party or vendor paymentsNo compliance programFacilitation

        Thirteen British mid-level managers employed by Harman's US subsidiary knew its UAE distributor was diverting ex-works shipments from Denmark to Iran, including to the Iranian government, and used euphemisms like 'North Dubai' and 'up north' in emails and discount approvals. Harman had one under-resourced trade compliance employee and no system for monitoring sanctions risk.

        “members of the British Sales Team used deceptive terms such as “the northern region,” “North Dubai,” and “up north””
        Mitigating and aggravating factors
        Mitigating
        • no penalty notice or Finding of Violation in prior five years
        • rigorous investigation with outside counsel and an auditor, substantial compliance investment, new reporting guidelines, more authority for legal and trade compliance, training
        Aggravating
        • sales team willfully sold to Iran and obscured it with euphemisms over years
        • mid-level managers had actual knowledge
        • Iranian government among end users, enabled by inadequate compliance
        • large sophisticated global company

        Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

        Jul 2, 2025Settlement$608,825

        Key Holding, LLC (for Key Logistics Colombia S.A.S.)

        Logistics and freight · Cuba program · 36 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

        No compliance programCustomer or counterparty due diligenceThird-party or vendor payments

        After Key Holding bought a Colombian freight broker in December 2021, the subsidiary arranged 36 shipments worth $3.06 million from suppliers in Colombia, Spain, China and Panama to consignees in Cuba, including one through majority state-owned Comercial Cupet. Neither parent nor subsidiary had any sanctions program, and the parent found the shipments only during diligence for its own sale.

        “Key Holding U.S. had no OFAC sanctions compliance program in place covering its non-U.S. subsidiaries”
        Mitigating and aggravating factors
        Mitigating
        • no penalty notice or Finding of Violation in prior five years
        • mostly benign consumer foodstuffs
        • stopped Cuba orders, first sanctions policy, mandatory training, continuous automated shipment screening
        • self-disclosure and high cooperation
        Aggravating
        • failed due caution by not addressing the ownership change that brought the subsidiary under US jurisdiction
        • subsidiary staff knew and parent had reason to know
        • undermined the Cuba embargo
        • freight forwarder with Colombian operations warranted extra care

        Source: OFAC enforcement release (PDF), United States (Colombian subsidiary); read Nov. 1, 2026.

        Jun 16, 2025Settlement$3,882,797

        Unicat Catalyst Technologies, LLC

        Manufacturing and trade (refinery catalysts) · Iran and Venezuela programs · violation count not stated · AP or vendor relevant · self-disclosed: yes · egregious: yes

        Third-party or vendor paymentsFacilitationCustomer or counterparty due diligence

        Unicat's former CEO signed distribution agreements with a UAE and Iran distributor and routed Iranian orders through a Dutch affiliate and a Chinese supplier office, sent engineers to Iranian refineries and took cash for on-site services to avoid US-linked transfers; staff later called Iran 'I' in emails. The board discussed the Iran business in 2018 and did nothing, and the company also sold to a blocked Venezuelan entity.

        “the “method of payment for these kind of invoices” should be in cash to “avoid from transfering [sic] money””
        Mitigating and aggravating factors
        Mitigating
        • no penalty notice or Finding of Violation in prior five years

        The release lists further factors; see the source.

        Aggravating
        • willful sales and services to Iran despite warnings from employees and outsiders
        • senior management directed the conduct and the board failed to intervene from 2018
        • concealment through omitted references, cash payments and rerouting through the Dutch affiliate
        • catalysts are key technology for Iranian and Venezuelan revenue sectors

        Note: concurrent DOJ and BIS resolutions; new ownership self-disclosed.

        Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

        Jun 12, 2025Penalty notice$215,988,868

        GVA Capital Ltd.

        Other: venture capital · Ukraine/Russia program · violation count not stated · AP or vendor relevant · self-disclosed: no · egregious: yes

        50 Percent Rule missedFacilitationCustomer or counterparty due diligence

        GVA Capital's founders pitched Kerimov at his French estate in 2016, took his $20 million through a vehicle called Prosperity, and after his 2018 designation kept managing the stake in a US company, which appreciated to as much as $436 million, and tried three times to sell or distribute it by working through his nephew-proxy. It did so despite May 2018 legal advice that any transfer indirectly involving Kerimov would violate sanctions.

        “GVA Capital nonetheless continued managing these investments by working through Kerimov’s nephew, Nariman Gadzhiev, who GVA Capital knew served as Kerimov’s proxy”
        Mitigating and aggravating factors
        Mitigating

        None stated in the release.

        Aggravating
        • willful violation with senior management's actual knowledge that Kerimov retained an interest
        • continued through the proxy after designation and against express legal advice
        • let a sanctioned oligarch's US investment grow to hundreds of millions and attempted to pay it out

        Note: statutory maximum imposed; includes a subpoena compliance violation.

        Source: OFAC enforcement release (PDF), United States (Cayman Islands registered, San Francisco based); read Nov. 1, 2026.

        Jan 17, 2025Settlement$1,044,781

        Haas Automation, Inc.

        Manufacturing and trade (CNC machine tools) · Ukraine/Russia and Belarus programs · 21 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: mixed

        50 Percent Rule missedThird-party or vendor paymentsScreening skipped data fieldsCustomer or counterparty due diligence

        Through its Russian distributor Abamet, Haas supplied a CNC machine, 13 spare parts orders and seven financial unlock codes to six entities that were SDNs or owned 50 percent or more by SDNs in Russia's defense sector, including a Russian Navy supplier. For seven customers it never checked ownership and for the eighth it failed to rescreen a designated customer before a parts sale.

        “For seven of the eight blocked entity customers, Haas failed to conduct sufficient due diligence regarding the blocked entities’ ownership structures”
        Mitigating and aggravating factors
        Mitigating
        • prompt remediation including a new screening tool that checks customer ownership, more staff, training for all distributor employees, audits of high-risk distributors, machine location tracking
        Aggravating
        • inadequate due diligence for over two years in a high-risk Russian customer base
        • seven of eight end users tied to Russia's defense sector and unlock codes kept their machines running

        Note: 8 of 21 violations egregious; concurrent BIS settlement of $1,500,000.

        Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

        Jan 16, 2025Settlement$1,076,923

        Family International Realty LLC and its owner

        Other: real estate brokerage and property management · Ukraine/Russia and Crimea programs · 73 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: yes

        Facilitation50 Percent Rule missed

        A Miami realtor who managed condos for two Russian oligarchs designated in 2018 texted one that 'it will soon be forbidden to deal with you', then helped move the properties into spouses' names and a Delaware shell owned by a minor child for $100 or no consideration, rented them out and sold one for $1.2 million, earning $182,442 in commissions. The owner pleaded guilty in a related DOJ case.

        ““it will soon be forbidden to deal with you...I talked with people who know [about this issue] here.””
        Mitigating and aggravating factors
        Mitigating
        • comprehensive resolution with DOJ including a guilty plea
        • cooperation
        • financial condition
        Aggravating
        • willful sophisticated evasion scheme with knowledge
        • actual knowledge and enlisted others
        • over five years, $2.1 million in proceeds for the oligarchs

        Note: owner also pleaded guilty in a DOJ resolution.

        Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

        Dec 31, 2024Settlement$22,172

        SkyGeek Logistics, Inc.

        Other: aviation parts supplier · Ukraine/Russia program · 6 apparent violations · AP or vendor relevant · self-disclosed: partial · egregious: no

        Screening skipped data fieldsThird-party or vendor paymentsLegacy or unintegrated system

        SkyGeek tried to refund $16,842 to Flavic FZE and $669 to Mirage Air Craft Services, two UAE parts suppliers designated under the Russia program, and shipped four small orders to Mirage after its designation. Its screening list did not yet reflect a same-day designation, and its policy was not to rescreen previously approved customers before refunds; downstream banks blocked both refunds.

        “Because its compliance protocol at the time was not to re-screen previously approved parties”
        Mitigating and aggravating factors
        Mitigating
        • no penalty notice or Finding of Violation in prior five years
        • ceased sales to 45 higher-risk jurisdictions, rescreening of all refund recipients including billing and shipping names and addresses, improved fuzzy logic, new screening vendor, training
        Aggravating
        • controls not commensurate with jurisdictional and industry risk
        • had reason to know since Flavic had been listed 56 days before the refund request

        Note: four of six transactions self-disclosed.

        Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

        Dec 18, 2024Settlement$45,179

        An Individual (corporate secretary and treasurer)

        Other: individual, professional services gatekeeper · Magnitsky program · 6 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: mixed

        Third-party or vendor paymentsFacilitation

        The secretary and treasurer of a two-person equine company kept executing payments at the direction of its CEO after the CEO was designated under Global Magnitsky, including $25,359 for the CEO's child's travel and school as indirect compensation and $19,820 for the CEO's UAE business, some run through a personal firm to earn card points. OFAC framed it as a gatekeeper failure.

        “U.S. Person-1 continued to fulfill their usual duties, which included executing payments on behalf of the SDN”
        Mitigating and aggravating factors
        Mitigating
        • very small volume over a brief period
        • extensive cooperation that shortened the investigation
        • no penalty notice or Finding of Violation in prior five years
        Aggravating
        • aware of the designation but reckless in not considering its implications
        • aware of the conduct at all times
        • gave the SDN access to US funds

        Note: three compensatory payments egregious, three others non-egregious.

        Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

        Dec 18, 2024Settlement$41,591

        Córdoba Music Group LLC

        Manufacturing and trade (musical instruments) · Iran program · 9 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

        Third-party or vendor paymentsNo compliance programCustomer or counterparty due diligence

        After meeting an Iranian distributor at an Anaheim trade show, Córdoba billed and shipped $118,831 of instruments to a Dubai trading company that forwarded them to Iran on nine occasions, believing indirect sales of instruments were allowed. A new owner found the draft Iran distribution agreement two months after acquiring the company and self-disclosed.

        “The new Iranian distributor instructed Córdoba to bill and ship products to a Dubai-based general trading company”
        Mitigating and aggravating factors
        Mitigating
        • small manufacturer with under 100 employees and no enforcement history
        • training, third-party screening requirements and sales order reviews
        • full cooperation
        Aggravating
        • traded with Iran without checking the law
        • employees and then-CEO knew products were destined for Iran

        Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

        Dec 13, 2024Settlement$257,690

        C.H. Robinson International Inc. (five foreign subsidiaries)

        Logistics and freight · Iran and Cuba programs · 82 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

        Legacy or unintegrated systemNo screening performedCustomer or counterparty due diligence

        Five acquired subsidiaries in China, Spain, Canada, Australia and Peru brokered 82 shipments to or from Iran, of Iranian or Cuban origin goods, or on Mahan Air, because their brokerage systems had not been integrated into CHR's screened platform for up to 4.5 years after acquisition. In one case staff reviewed an air waybill showing carrier code W5 and first destination IKA without recognizing Mahan Air or Tehran.

        “the subsidiaries’ brokerage management systems had not yet been incorporated into CHR’s system or otherwise updated to include the latest sanctions compliance controls”
        Mitigating and aggravating factors
        Mitigating
        • no penalty notice or Finding of Violation in prior five years
        • manual holds on flagged shipments, trade compliance task force, mandatory OFAC training, nearly all offices on the central system

        The release lists further factors; see the source.

        Aggravating
        • failed due caution after acquisitions for up to 4.5 years
        • had reason to know from shipment documents
        • harm to two sanctions programs
        • large sophisticated global logistics company

        Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

        Dec 3, 2024Settlement$14,550,000

        Aiotec GmbH

        Other: industrial equipment sourcing for energy sector · Iran program · 1 apparent violation · AP or vendor relevant · self-disclosed: no · egregious: yes

        FacilitationThird-party or vendor payments

        Aiotec bought a decommissioned Australian polypropylene plant from a US broker for $9.7 million under a contract barring resale to sanctioned countries, signed three false end-user certificates naming a Turkish partner, told freight forwarders to report the UAE or Türkiye to Australian customs, and shipped the plant to Iran while paying through US banks. It had signed the resale contract with an Iranian petrochemical company two days after the purchase.

        “instructed the freight forwarders not to register the end user’s name and address as “Iran” with Australia’s customs office”
        Mitigating and aggravating factors
        Mitigating

        None stated in the release.

        Aggravating
        • willful conspiracy despite repeated contractual and written reminders from the US company
        • managing directors made false representations and signed false end-user certificates for four years
        • substantial harm by giving Iran a hard-to-obtain petrochemical plant

        Source: OFAC enforcement release (PDF), Germany; read Nov. 1, 2026.

        Nov 19, 2024Penalty notice$1,104,408

        An Individual (US person hotel investor in Iran)

        Other: individual · Iran program · 75 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: yes

        Facilitation

        A US person bought, renovated and ran a 19-suite hotel in Iran, moving about $561,802 through a Canadian money services business that used informal value transfer, paying US-based strangers by check so rials would be credited to accounts at blocked Iranian banks. After one bank closed the accounts the person resumed at another bank through company accounts with smaller, unlabeled checks.

        “U.S. Person-1 used foreign money services businesses in Iran and Canada to evade U.S. sanctions”
        Mitigating and aggravating factors
        Mitigating
        • little sanctions expertise and no prior enforcement action
        • financial condition warranted significant mitigation
        Aggravating
        • reckless and in part willful conduct knowing transfers were prohibited
        • actual knowledge throughout
        • invested over half a million dollars in Iran and gave liquidity to two blocked Iranian banks
        • not fully cooperative

        Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

        Nov 14, 2024Settlement$178,421

        American Life Insurance Company (ALICO, MetLife subsidiary)

        Insurance · Iran program · 2,331 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

        Alerts cleared wronglyCustomer or counterparty due diligence50 Percent Rule missedScreening skipped data fieldsThird-party or vendor payments

        After compliance rejected a UAE school owned by the Iranian embassy, the same sales agent resubmitted it through a third-party administrator with a trade license stripped of the owner line, and ALICO issued the policy because nothing tracked previously rejected applicants; it then accepted $78,143 in cash after a premium check drawn on Bank Melli bounced. In all it collected 2,331 premiums and claims for Iranian government-owned schools.

        “there was no system in place to flag applications that had previously been rejected”
        Mitigating and aggravating factors
        Mitigating
        • no Finding of Violation or penalty notice in prior five years
        • alerts when a sanctioned country name appears in an entity name, tracking of rejected applicants, training on country-based sanctions
        Aggravating
        • onboarding failed to stop GOI entities and a rejected applicant re-applied successfully
        • had reason to know from GOI letterhead and the Bank Melli check rejection
        • $446,038 in transactions for GOI entities over 18 months
        • large sophisticated insurer owned by MetLife

        Source: OFAC enforcement release (PDF), United States (UAE operations); read Nov. 1, 2026.

        Oct 17, 2024Settlement$860,000

        Vietnam Beverage Company Limited (two subsidiaries)

        Manufacturing and trade (alcoholic beverages) · North Korea program · 43 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

        No compliance programThird-party or vendor paymentsCustomer or counterparty due diligence

        VBCL's subsidiaries signed 26 contracts to sell beer and spirits to two North Korean trading companies and two third-country fronts, invoiced in USD, and received 43 wires totaling $1.14 million from 15 unrelated payers in Hong Kong, China and Turkey through US correspondent banks. Nearly every document named North Korea and no sanctions program existed.

        “received 43 wire transfers totaling approximately $1,141,547 between April 2016 and October 2018 for these sales from 15 different third-party companies”
        Mitigating and aggravating factors
        Mitigating
        • no penalty notice in prior five years
        • substantial cooperation including research on similar violations and multiple tolling agreements
        • self-initiated program modeled on the OFAC Framework, compliance teams, third-party screening, training
        Aggravating

          The release lists further factors; see the source.

          Note: proactive notification to OFAC credited as cooperation but not as a VSD.

          Source: OFAC enforcement release (PDF), Vietnam; read Nov. 1, 2026.

          Jul 26, 2024Settlement$7,452,501

          State Street Bank and Trust Company and Charles River Systems, Inc.

          Software (financial technology subsidiary of a bank) · Ukraine/Russia program · 38 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: yes

          Alerts cleared wrongly50 Percent Rule missedCustomer or counterparty due diligenceNo compliance program

          Charles River staff re-dated or reissued invoices, one as many as six times, so that subsidiaries of Sberbank and VTB could pay for its trading network outside the 30- and 14-day debt tenors of Directive 1, after a US bank had rejected late payments and sent sanctions guidance. At least 18 staff were involved, and after State Street's 2018 acquisition its staff dismissed screening alerts on the payments for 19 more months.

          “she would, “do whatever it takes to get this invoice paid.””
          Mitigating and aggravating factors
          Mitigating
          • cooperation including proactive notification

          The release lists further factors; see the source.

          Aggravating
          • recklessly re-dated invoices and accepted late payments over four years knowing of sanctions limits
          • continued despite rejection notices citing E.O. 13662 and bank guidance
          • at least 18 staff involved and State Street dismissed alerts for 19 months post-acquisition
          • commercially sophisticated

          Note: proactive notification to OFAC credited as cooperation but not as a VSD.

          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

          Jun 26, 2024Settlement$538,000

          Mondo TV, S.p.a.

          Other: animation production · North Korea program · 18 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

          Third-party or vendor paymentsNo compliance programFacilitation

          Mondo paid about $538,000 in 18 wires for outsourced animation work by SEK Studio, a North Korean government-owned studio, sending the money as instructed by SEK's invoices to two Chinese companies and a US company with accounts at US banks. The CEO signed contracts naming North Korea and the COO and head of legal approved every payment; there was no sanctions policy.

          “SEK would issue an invoice to Mondo that named a third-party company and its bank account details for Mondo to remit payment”
          Mitigating and aggravating factors
          Mitigating

            The release lists further factors; see the source.

            Aggravating
            • reckless disregard in routing DPRK payments through US banks
            • senior management knew it was paying a DPRK entity through US-account intermediaries
            • revenue for the North Korean regime

            Source: OFAC enforcement release (PDF), Italy; read Nov. 1, 2026.

            Apr 19, 2024Settlement$20,000,000

            SCG Plastics Co., Ltd.

            Other: plastic resin trading · Iran program · 467 apparent violations · AP or vendor relevant · self-disclosed: partial · egregious: yes

            FacilitationThird-party or vendor payments

            SCG Plastics resold HDPE made by Mehr, an Iranian joint venture of its parent and the National Petrochemical Company of Iran, invoicing East Asian customers in USD with 'Middle East' as origin and Jebel Ali as loading port after transshipping through the UAE, so US correspondent banks cleared $291 million. It also paid Mehr's vendor debts in USD, labeling them 'payment for goods'.

            “listed variants of the term “Middle East” as the country of origin rather than “Iran,””
            Mitigating and aggravating factors
            Mitigating
            • no penalty notice or Finding of Violation in prior five years
            • substantial cooperation including an independent internal investigation
            Aggravating
            • willful multi-year concealment of Iranian origin to evade bank detection
            • significant benefit to Iran's petrochemical sector and paid Mehr's debts including to other Iranian companies
            • sophisticated and a significant share of revenue came from the violations

            Note: ten transactions self-disclosed; successor Thai Polyethylene agreed to five years of compliance commitments.

            Source: OFAC enforcement release (PDF), Thailand; read Nov. 1, 2026.

            Mar 14, 2024Settlement$3,740,442

            EFG International AG

            Banking (private banking group) · Cuba and Narcotics and Ukraine/Russia programs · 873 apparent violations · not an AP or vendor case · self-disclosed: yes · egregious: no

            Screening skipped data fieldsCustomer or counterparty due diligence50 Percent Rule missed

            EFG subsidiaries traded US securities through omnibus accounts at US custodians for Cuban residents and Cuban-owned companies, and for a Kingpin-designated client whose sub-account EFG Singapore froze internally but never disclosed to its US custodian for four years, so dividends kept flowing. A 2023 notification for a Russia-designated client missed three pledged positions held in EFG's own name.

            “EFG Singapore did not notify its U.S. custodian or other U.S. securities firms transacting with the omnibus account”
            Mitigating and aggravating factors
            Mitigating
            • internal restrictions stopped blocked clients benefiting
            • no penalty notice or Finding of Violation in prior five years
            • restrictions on sanctioned-client accounts and compliance approval for heightened-risk customers
            Aggravating
            • failed to screen and timely notify US custodians of blocked persons' positions in omnibus accounts
            • knew or had reason to know it held securities for blocked persons
            • 727 Cuba transactions worth $29.9 million over four years

            Source: OFAC enforcement release (PDF), Switzerland; read Nov. 1, 2026.

            Dec 21, 2023Settlement$466,200

            Privilege Underwriters Reciprocal Exchange (PURE)

            Insurance · Ukraine/Russia program · 39 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

            50 Percent Rule missedScreening skipped data fieldsCustomer or counterparty due diligence

            PURE kept insuring Medallion, Inc., a Panamanian company wholly owned by Viktor Vekselberg, for over two years after his 2018 designation, collecting 38 premiums and paying a $7,500 claim. Underwriters had the 2010 shareholder disclosure naming Vekselberg but never loaded ownership data into the underwriting system that fed screening, and non-US policyholders were not escalated.

            “PURE’s underwriters failed to upload the shareholder information from the corporate disclosure statement into PURE’s underwriting systems”
            Mitigating and aggravating factors
            Mitigating
            • no Finding of Violation or penalty in prior five years
            • rescreened entire customer base with two vendor tools, mandatory upload of corporate disclosure statements, escalation of non-US entities
            • cooperation and tolling
            Aggravating
            • failed to incorporate ownership information into screening and did nothing after the 2014 50 Percent Rule guidance until a 2022 inquiry
            • had reason to know from the 2010 ownership disclosure
            • paid a claim to and collected premiums from a blocked person

            Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

            Dec 13, 2023Settlement$1,207,830

            CoinList Markets LLC

            Fintech and digital assets (virtual currency exchange) · Crimea and Ukraine/Russia programs · 989 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: no

            Screening skipped data fieldsCustomer or counterparty due diligence

            CoinList opened 89 accounts for users who listed Russia as country of residence but gave Crimean cities or the word Crimea in their street address, and its onboarding filter keyed only on the country field. The users made 989 transactions worth $1.25 million over two years.

            “CLM’s screening protocols failed to recognize that “Crimea” or a city name in Crimea, provided in another data field, indicated likely residence in Crimea”
            Mitigating and aggravating factors
            Mitigating
            • no penalty notice or Finding of Violation in prior five years
            • cooperation including transaction data and tolling
            • very small share of volume
            • filter now rejects Crimean city addresses regardless of country field, IP geoblocking, VPN detection, new ID verification vendors, more staff
            Aggravating
            • no controls to flag self-described Crimea residents
            • knew or had reason to know from self-reported addresses
            • $1.25 million benefit to Crimea with no humanitarian purpose

            Note: $300,000 suspended pending compliance commitments and $300,000 compliance investment credited.

            Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

            Dec 8, 2023Settlement$4,040,923

            Nasdaq, Inc. (for Nasdaq OMX Armenia OJSC)

            Other: exchange operator · Iran and WMD programs · 151 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

            Customer or counterparty due diligenceNo compliance program50 Percent Rule missed

            Nasdaq's Armenian stock exchange subsidiary matched overnight loan and FX trades for Mellat Armenia, the SDN-listed subsidiary of Iran's Bank Mellat, and invoiced it monthly for participation and trading fees, for two years after US-owned foreign subsidiaries became subject to the Iran rules. The bank was publicly listed as a member but nobody saw the sanctions issue until 2014.

            “Nasdaq OMX Armenia charged and invoiced participating banks, including Mellat Armenia, for monthly participation fees and terminal fees”
            Mitigating and aggravating factors
            Mitigating
            • no penalty notice or Finding of Violation in prior five years
            • voluntary self-disclosure and tolling
            • actual harm far below face value of trades
            • later eligible for a license
            • divested the subsidiary, sanctions working group, new training, enhanced screening
            Aggravating
            • failed due caution contrary to applicable sanctions and Nasdaq policy
            • actual knowledge of Mellat Armenia's trading but no controls after 2012
            • large sophisticated international financial services corporation

            Source: OFAC enforcement release (PDF), United States (Armenian subsidiary); read Nov. 1, 2026.

            Nov 21, 2023Settlement$968,618,825

            Binance Holdings, Ltd.

            Fintech and digital assets (virtual currency exchange) · Iran and Cuba and Syria and North Korea and Crimea and Ukraine/Russia and SDN/counterterrorism programs · 1,667,153 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: yes

            Geolocation or IP data ignoredNo compliance programCustomer or counterparty due diligenceFacilitation

            For over five years Binance's matching engine paired US users with users in sanctioned jurisdictions and blocked persons in 1.67 million trades while senior management ran what OFAC called a paper compliance program, told staff to support Iranian customers 'non-openly', encouraged VPN use and allowed trades from sanctioned-jurisdiction IP addresses if KYC documents came from elsewhere. The settlement is the largest in OFAC history.

            “I understand that we still support [I]ranian customers but that has to be done non-openly.”
            Mitigating and aggravating factors
            Mitigating

            None stated in the release.

            Aggravating
            • knew conduct violated US law, reflected in CEO and CCO statements
            • knew matching engines routinely paired US and sanctioned-jurisdiction users
            • misrepresented controls to third parties and the public, removed sanctioned countries from its website, encouraged VPNs
            • economic benefit to many persons in sanctioned jurisdictions and at least two blocked persons over four years

            Note: concurrent DOJ, FinCEN and CFTC resolutions and a five-year independent compliance monitor.

            Source: OFAC enforcement release (PDF), Cayman Islands; read Nov. 1, 2026.

            Nov 6, 2023Settlement$206,213

            Swift Prepaid Solutions, Inc. d/b/a daVinci Payments

            Payments (prepaid reward cards) · Crimea and Iran and Syria and Cuba programs · 12,391 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

            Geolocation or IP data ignoredScreening skipped data fields

            daVinci redeemed 12,378 prepaid reward cards for users whose IP addresses were in Iran, Syria, Cuba or Crimea and 13 more for users with .ir or .sy email domains, totaling $549,135. Users were list-screened and could not enter a sanctioned address, but IP and email domain data were not used.

            “This case further demonstrates the potential shortcomings of controls that rely on customer-provided information”
            Mitigating and aggravating factors
            Mitigating
            • no Finding of Violation or penalty notice in prior five years
            • self-initiated review, IP blocking, real-time email suffix screening, periodic independent testing
            • cooperation
            Aggravating
            • knew or had reason to know from IP addresses and email suffixes but did not use them

            Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

            Sep 21, 2023Settlement$31,868

            Emigrant Bank

            Banking · Iran program · 30 apparent violations · not an AP or vendor case · self-disclosed: yes · egregious: no

            Alerts cleared wronglyScreening skipped data fieldsCustomer or counterparty due diligence

            Emigrant held a certificate of deposit for 26 years for two people resident in Iran, with their Iranian address on letters, tax forms and statements, and processed 30 transfers to relatives in the US. A 2016 filter stop was cleared as a permissible remittance, and a 2019 alert after the country code was changed to Iran was overridden on the strength of that earlier error.

            “Emigrant employees overrode the alert because they relied on the erroneous guidance from 2016”
            Mitigating and aggravating factors
            Mitigating
            • no Finding of Violation or penalty notice in prior five years
            • restricted and closed the account, fixed customer country data, screened permanent addresses
            • voluntary self-disclosure and tolling
            • negligible harm since payments went to US-resident family
            Aggravating
            • no controls to identify services to Iranian residents despite knowing their location
            • sophisticated longstanding bank
            • violations long after the ITSR were issued

            Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

            Sep 21, 2023Settlement$9,618,477

            3M Company (for 3M (East) AG and 3M Gulf)

            Manufacturing and trade · Iran program · 54 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: yes

            Screening skipped data fieldsCustomer or counterparty due diligenceFacilitationThird-party or vendor payments

            3M Gulf managers sold reflective license plate sheeting through a German reseller to Bonyad Taavon Naja, an entity controlled by Iran's Law Enforcement Forces and excluded from General License H. The restricted party screening request omitted the page listing the Iranian end user, so only the German reseller was screened, and the managers hid the change to a straight resale and a due diligence report flagging the police link.

            “only the German company was screened and not the actual Iranian end-user”
            Mitigating and aggravating factors
            Mitigating
            • risk-based OFAC compliance program in place
            • thorough investigation, six employees terminated or reprimanded, Trade Compliance counsel added, re-review of changed proposals
            • voluntary self-disclosure, substantial cooperation and tolling
            Aggravating
            • 3M Gulf senior managers willfully exported to a prohibited Iranian entity and others were reckless in ignoring evidence
            • actual knowledge of the end user months before signing
            • BTN is controlled by Iran's Law Enforcement Forces

            Source: OFAC enforcement release (PDF), United States (Swiss and UAE subsidiaries); read Nov. 1, 2026.

            Aug 16, 2023Settlement$660,594

            Construction Specialties Inc. (for Construction Specialties Middle East L.L.C.)

            Manufacturing and trade (building materials) · Iran program · 3 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: yes

            FacilitationThird-party or vendor payments

            The general manager of CS's Dubai subsidiary imported building materials from the US parent and another US supplier and re-exported them for a Tehran shopping mall, falsifying destinations on seven purchase orders, using a false project name, removing US-origin labels and commingling goods. A US-person employee who noticed unexplained expenses was fired the day he confronted the GM and flew home to report it.

            “the senior managers falsified the ultimate destination of goods on seven purchase orders to the U.S. suppliers”
            Mitigating and aggravating factors
            Mitigating
            • US headquarters unaware
            • compliance program reasonably designed for the rules then in force
            • immediate terminations, internal investigation, new compliance personnel and policies
            • prompt disclosure, timely responses and tolling
            Aggravating
            • two senior managers willfully bought US products to sell to Iran knowing it was impermissible

            The release lists further factors; see the source.

            Note: year table shows 660,954; release text says 660,594.

            Source: OFAC enforcement release (PDF), United States (UAE subsidiary); read Nov. 1, 2026.

            Jun 20, 2023Settlement$3,430,900

            Swedbank Latvia AS

            Banking · Crimea program · 386 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: no

            Geolocation or IP data ignoredScreening skipped data fieldsAlerts cleared wronglyCustomer or counterparty due diligence

            A Crimea-based shipping client used Swedbank Latvia's e-banking from Crimean IP addresses to send 386 payments worth $3.3 million to Crimea through US correspondents. When one US bank rejected payments for a Crimea link, a relationship manager accepted the client's false assurance and re-routed them through another US correspondent, even though KYC files showed the Crimean presence and IP data was stored but not screened.

            “a relationship manager at Swedbank Latvia re-routed the rejected payments to a different U.S. correspondent bank”
            Mitigating and aggravating factors
            Mitigating
            • no penalty notice or Finding of Violation in prior five years
            • exited the clients, IP geofencing on online banking, control to detect resubmitted rejected payments, enhanced due diligence for USD payers, more staff
            • extensive lookback and cooperation
            Aggravating
            • ignored KYC and IP data in its possession and relied on client assurances
            • knew it had Crimean customers
            • sophisticated institution with over one million customers

            Note: a third party notified OFAC first.

            Source: OFAC enforcement release (PDF), Latvia; read Nov. 1, 2026.

            May 17, 2023Settlement$3,509,286

            Murad, LLC and a former senior executive

            Manufacturing and trade (cosmetics) · Iran program · 4 apparent violations · AP or vendor relevant · self-disclosed: partial · egregious: yes

            Third-party or vendor paymentsNo compliance programFacilitation

            Murad signed exclusive distribution agreements with an Iranian distributor and then a related UAE distributor and exported over $11 million of cosmetics to Iran in at least 62 shipments over eight years, applying for licenses it never received, and kept shipping after Unilever's counsel ordered a stop. A Murad.ir site sold the products for three years after the acquisition and compliance reporting ran to a UK Unilever unit unfamiliar with OFAC.

            “the Company nonetheless completed shipments to Iran via the UAE Distributor, through departments generally overseen by U.S. Person-1”
            Mitigating and aggravating factors
            Mitigating

            None stated in the release.

            Aggravating
            • willful conspiracy knowing a license was required, continued after Unilever's instruction
            • senior executives had actual knowledge of the agreements, exports and support for a Tehran store over eight years

            Note: company self-disclosed after acquisition by Unilever US ($3,334,286); the executive did not ($175,000); release lists one company violation and three individual violations.

            Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

            May 1, 2023Settlement$7,591,630

            Poloniex, LLC

            Fintech and digital assets (digital asset trading platform) · Crimea and Cuba and Iran and Sudan and Syria programs · 65,942 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: no

            Geolocation or IP data ignoredNo compliance programCustomer or counterparty due diligenceLegacy or unintegrated system

            Poloniex ran for 16 months with no sanctions program, then screened only new customers' KYC addresses without rescreening existing ones, monitored but did not block sanctioned-jurisdiction IP logins until mid-2017 and added Crimea controls only in August 2017. In all 232 customers in Crimea, Cuba, Iran, Sudan and Syria made 65,942 transactions worth $15.3 million.

            “existing customers were not retroactively screened in this manner”
            Mitigating and aggravating factors
            Mitigating
            • no penalty notice or Finding of Violation for Poloniex or Circle in prior five years
            • small start-up at the time
            • Circle's post-acquisition controls including KYC freezes, automated ID verification, profile matching, geolocation restrictions and closing Crimea accounts
            Aggravating
            • no sanctions program for over a year and inconsistent application to pre-existing accounts
            • had reason to know from physical address and IP data
            • economic benefit to 232 persons in sanctioned jurisdictions

            Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

            Apr 25, 2023Settlement$508,612,492

            British American Tobacco p.l.c.

            Manufacturing and trade (tobacco) · North Korea and WMD programs · 15 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: yes

            FacilitationThird-party or vendor payments50 Percent Rule missed

            BAT's top executives approved a sham divestment of its North Korean cigarette joint venture to a Singapore company for one euro while retaining control, then collected $251.6 million in 228 USD payments routed from designated North Korean banks through Chinese front company accounts to a US bank branch. Its Singapore unit also sold cigarettes to the DPRK Embassy and scrubbed the embassy's name from documents.

            “letting a wire transfer expire rather than respond to a question from a bank that would have revealed the payment’s connection to North Korea”
            Mitigating and aggravating factors
            Mitigating
            • no OFAC investigation, Finding of Violation or penalty notice in prior five years
            • cooperation including tolling and detailed productions
            Aggravating
            • willful conspiracy to move hundreds of millions through US banks with management aware of the prohibition
            • concealment through sham divestment, front companies and ignoring bank questions
            • Standing Committee had actual knowledge
            • helped North Korea build a cigarette business funding proliferation
            • large sophisticated company in 180 markets

            Note: settlement equals the statutory maximum; 1 WMDPSR conspiracy violation plus 14 NKSR violations per release.

            Source: OFAC enforcement release (PDF), United Kingdom; read Nov. 1, 2026.

            Apr 6, 2023Settlement$2,980,266

            Microsoft Corporation (with Microsoft Ireland Operations and Microsoft Rus)

            Software · Cuba and Iran and Syria and Ukraine/Russia and Crimea programs · 1,339 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

            Third-party or vendor paymentsScreening skipped data fields50 Percent Rule missedName matching false negativeCustomer or counterparty due diligence

            Through distributors and resellers Microsoft sold and activated $12.1 million of licenses from US and Irish servers for SDNs, blocked persons and users in Cuba, Iran, Syria, Russia and Crimea, often without knowing the end customer; Russian staff even used a pseudonym to order for a rejected SDN subsidiary. Screening did not aggregate name, address and tax ID across databases, rescreen existing customers after list changes, catch entities 50 percent owned by SDNs, or match Cyrillic and Chinese names.

            “did not identify blocked parties not specifically listed on the SDN List, but owned 50 percent or more by SDNs”
            Mitigating and aggravating factors
            Mitigating
            • no evidence US offices or management knew; self-initiated lookback and comprehensive investigation
            • voluntary self-disclosure and voluminous cooperation
            • terminated accounts and deactivated license keys, updated suspension procedures
            • significant remedial measures
            Aggravating
            • reckless disregard over seven years for $12 million of exports to prohibited parties, with reason to know
            • benefited more than 100 SDNs or blocked persons including major Russian enterprises
            • world-leading technology company with substantial expertise

            Note: joint action with BIS, which settled for $624,013 and credited $276,382.

            Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

            Mar 31, 2023Settlement$72,230

            Uphold HQ Inc.

            Fintech and digital assets (digital trading platform and money services business) · Iran and Cuba and Venezuela programs · 152 apparent violations · not an AP or vendor case · self-disclosed: yes · egregious: no

            Screening skipped data fieldsCustomer or counterparty due diligence

            Uphold onboarded customers who picked a non-sanctioned country from a dropdown but typed Iran or Cuba in the free-text address field, or uploaded ID documents from sanctioned countries, and screened neither. It also processed payments for two self-identified PdVSA employees after collecting employment data it did not use for sanctions until May 2022.

            “also indicated their location in a sanctioned jurisdiction (i.e., Iran or Cuba) in the free text address field, which Uphold did not screen”
            Mitigating and aggravating factors
            Mitigating
            • no penalty notice or Finding of Violation in prior five years
            • timely cooperation and tolling
            • suspended the users, IT solution to screen free text fields and ID documents, weekly QA testing, independent testing, automatic restrictions on transfers to sanctioned jurisdictions
            Aggravating
            • failed due caution in onboarding and diligence with inadequate screening
            • had reason to know from information users provided at account opening

            Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

            Mar 30, 2023Settlement$30,000,000

            Wells Fargo Bank, N.A. (and predecessor Wachovia)

            Banking · Iran and Syria and Sudan programs · 124 apparent violations · not an AP or vendor case · self-disclosed: yes · egregious: yes

            FacilitationLegacy or unintegrated system

            A Wachovia mid-level manager customized a hosted version of the Eximbills trade finance platform so a European bank could run letters of credit involving Iran, Syria and Sudan on it, with the software even redirecting such transactions away from Wachovia's own processing queue. Wells Fargo inherited the arrangement in 2008 and, despite internal concerns raised to senior management, did not identify it for seven years.

            “Wachovia, at the direction of this mid-level manager, specially designed a customized version of Eximbills for Bank A”
            Mitigating and aggravating factors
            Mitigating
            • not a systemic breakdown and historically strong overall program

            The release lists further factors; see the source.

            Aggravating
            • legacy unit recklessly built a platform it knew would handle sanctioned-jurisdiction trade finance
            • no review for seven years despite internal concerns at senior levels
            • a mid-level manager led the project and senior management should have known
            • platform made it easier for the European bank to run such transactions

            Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

            Mar 1, 2023Settlement$332,500

            Godfrey Phillips India Limited

            Manufacturing and trade (tobacco) · North Korea program · 5 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

            FacilitationThird-party or vendor paymentsCustomer or counterparty due diligence

            GPI sold 79,200 kg of tobacco for a North Korean customer through a Thai intermediary, deciding internally not to put DPR Korea on the bill of lading and listing the Thai company and China instead. Four Hong Kong intermediaries paid $369,228 in USD into GPI accounts, routing the money through US correspondent banks and a US bank's Indian branch.

            “right now the question is whether GPI as a company is willing to write DPR Korea on the BL [bill of lading]”
            Mitigating and aggravating factors
            Mitigating
            • no penalty notice or Finding of Violation in prior five years
            • sanctions compliance policy with screening, KYC and recordkeeping adopted in January 2022
            • timely organized cooperation and tolling
            Aggravating
            • reckless in causing US banks to facilitate tobacco exports to the DPRK
            • several managers had actual knowledge
            • revenue-generating good to the North Korean regime

            Source: OFAC enforcement release (PDF), India; read Nov. 1, 2026.

            Dec 30, 2022Settlement$4,379,810

            Danfoss A/S (for Danfoss FZCO)

            Manufacturing and trade (refrigeration and cooling equipment) · Iran and Syria and Sudan programs · 225 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

            Third-party or vendor paymentsScreening skipped data fieldsNo compliance program

            Danfoss's UAE subsidiary told customers in Iran, Syria and Sudan to pay into its account at the UAE branch of a US bank, and those customers paid through money exchangers in other countries, which hid the originators from the bank's filters; it also paid Iranian and Syrian parties the same way. The parent had no procedure to monitor the subsidiary, and the regional finance director lacked sanctions training despite bank rejections and compliance warnings.

            “The use of third-party payers disguised the originator or beneficiary of these transactions”
            Mitigating and aggravating factors
            Mitigating

            None stated in the release.

            Aggravating
            • four years of insufficient caution using the US branch account for sanctioned-country customers
            • actual knowledge of the counterparties' locations
            • third-party payers prevented the US bank branch from screening

            Note: disclosure made after the bank had reported, not treated as voluntary.

            Source: OFAC enforcement release (PDF), Denmark (UAE subsidiary); read Nov. 1, 2026.

            Nov 28, 2022Settlement$362,159

            Payward, Inc. (Kraken)

            Fintech and digital assets (virtual currency exchange) · Iran program · 826 apparent violations · not an AP or vendor case · self-disclosed: yes · egregious: no

            Geolocation or IP data ignored

            Kraken checked IP addresses at onboarding to keep out users in sanctioned countries but did not block IP addresses on later transactions, so account holders who signed up elsewhere traded 826 times from Iran. It later added transaction-level geoblocking, blockchain analytics and 50 Percent Rule ownership screening.

            “Kraken did not implement IP address blocking on transactional activity across its platform”
            Mitigating and aggravating factors
            Mitigating
            • no penalty notice or Finding of Violation in prior five years
            • voluntary self-disclosure and cooperation
            • geolocation blocking, blockchain analytics, head of sanctions, 50 Percent Rule screening, ID verification vendor, Crimea and Donbas postal code blocking
            Aggravating
            • applied geolocation controls only at onboarding despite IP evidence of transactions from Iran

            Note: plus $100,000 additional compliance investment.

            Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

            Oct 18, 2022Finding of violationno penalty

            Nodus International Bank, Inc.

            Banking · Venezuela program · 3 apparent violations · not an AP or vendor case · self-disclosed: yes · egregious: not stated

            No compliance program

            After a customer was designated, Nodus blocked his accounts but redeemed his securities without the OFAC license it knew it needed, let an automatic debit hit a blocked account to pay a blocked credit card, then wrote the card off. It also lost records about the blocked property after its compliance officer left and filed inconsistent annual blocked property reports.

            “its systems did not effectively retain such records or communications”
            Mitigating and aggravating factors
            Mitigating
            • small institution with no prior penalty notice or FOV
            • voluntary self-disclosure of the VSR violations
            • sanctions harm not significant
            • OFAC training, in-house lawyer, blocked account labeling, software controls, updated recordkeeping
            Aggravating
            • dealt in blocked property without a license though senior managers knew one was needed
            • failed to maintain records, impairing full and accurate information to OFAC

            Note: Finding of Violation in lieu of penalty; also cited for recordkeeping (31 CFR 501.601) and inaccurate blocked property reports.

            Source: OFAC enforcement release (PDF), United States (Puerto Rico); read Nov. 1, 2026.

            Oct 11, 2022Settlement$24,280,829

            Bittrex, Inc.

            Fintech and digital assets (virtual currency exchange) · Crimea and Cuba and Iran and Sudan and Syria programs · 116,421 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: no

            Geolocation or IP data ignoredScreening skipped data fieldsNo compliance programCustomer or counterparty due diligence

            Bittrex ran 1,730 accounts for users in Crimea, Cuba, Iran, Sudan and Syria that made 116,421 transactions worth $263 million, with no sanctions program for nearly two years and then a vendor that screened only against the SDN List and not for sanctioned locations. It held IP addresses, physical addresses and even Iranian passports but did not screen them until an OFAC subpoena arrived.

            “the vendor screened transactions only for hits against OFAC’s List of Specially Designated Nationals and Blocked Persons”
            Mitigating and aggravating factors
            Mitigating

            None stated in the release.

            Aggravating
            • no sanctions compliance program from March 2014 to February 2016
            • vendor screening covered only SDN hits, not sanctioned locations, for over four years despite location data

            The release lists further factors; see the source.

            Note: part of a global resolution with FinCEN.

            Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

            Sep 30, 2022Settlement$116,049

            Tango Card, Inc.

            Payments (electronic rewards and stored value) · Cuba and Iran and Syria and North Korea and Crimea programs · 27,720 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

            Geolocation or IP data ignoredScreening skipped data fields

            Tango Card sent 27,720 gift cards and promotional debit cards worth $386,829 to reward recipients whose email domains (.ir, .cu) or redemption IP addresses pointed to Cuba, Iran, Syria, North Korea or Crimea. It screened its direct business customers and used geolocation for fraud, but not for the recipients of rewards.

            “it did not use those controls to identify whether recipients of rewards, as opposed to senders of rewards, might involve sanctioned jurisdictions”
            Mitigating and aggravating factors
            Mitigating
            • no penalty notice or Finding of Violation in prior five years
            • geoblocking of TLDs and IPs, training, more staff, new screening tools, monthly lookback reports

            The release lists further factors; see the source.

            Aggravating
            • failed to apply available geolocation tools to reward recipients despite IP and TLD data
            • up to $386,829 benefit to sanctioned jurisdictions

            Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

            Sep 26, 2022Settlement$401,039

            CFM Indosuez Wealth

            Banking (wealth management) · Cuba and Iran and Syria programs · 426 apparent violations · not an AP or vendor case · self-disclosed: yes · egregious: no

            Screening skipped data fieldsCustomer or counterparty due diligenceLegacy or unintegrated system

            CFM held USD accounts for 11 individuals whose KYC files showed residence in Cuba, Iran or Syria and let them buy US securities and make payments through US brokers and correspondents for five years. Internal restrictions added in 2015 did not stop securities-related credits.

            “these internal restrictions did not prevent securities-related payments from being credited to the accounts”
            Mitigating and aggravating factors
            Mitigating
            • no penalty notice or Finding of Violation in prior five years
            • implemented group escalation rules for clients resident in sanctioned countries and other remediation
            Aggravating
            • personnel had reason to know from KYC address data
            • $1.23 million benefit to persons in sanctioned countries over five years

            Source: OFAC enforcement release (PDF), Monaco; read Nov. 1, 2026.

            Sep 26, 2022Settlement$720,258

            CA Indosuez (Switzerland) S.A.

            Banking (wealth management) · Cuba and Crimea and Iran and Sudan and Syria programs · 273 apparent violations · not an AP or vendor case · self-disclosed: yes · egregious: no

            Screening skipped data fieldsCustomer or counterparty due diligenceLegacy or unintegrated system

            CAIS held USD accounts for 17 individuals resident in Iran, Syria, Sudan, Crimea and Cuba per their KYC files and processed 273 US securities and commercial transactions worth $3.08 million for them over three years. Restrictions introduced in 2014 and 2015 did not block securities-related payments.

            “the account holders’ know-your-customer (KYC) files included corresponding address information indicating their residence in sanctioned jurisdictions”
            Mitigating and aggravating factors
            Mitigating

            None stated in the release.

            Aggravating

              The release lists further factors; see the source.

              Source: OFAC enforcement release (PDF), Switzerland; read Nov. 1, 2026.

              Jul 21, 2022Finding of violationno penalty

              MidFirst Bank

              Banking · WMD program · 34 apparent violations · not an AP or vendor case · self-disclosed: not stated · egregious: not stated

              Screening skipped data fieldsLegacy or unintegrated system

              MidFirst kept accounts open and processed 34 payments, including $604,000 within six hours, for two customers for 14 days after they were designated, because its vendor rescreened the full customer base only monthly while the bank believed it was daily. The bank's own rescreening was also monthly.

              “the vendor only screened MidFirst’s entire existing customer base once a month”
              Mitigating and aggravating factors
              Mitigating
              • violations within two weeks and 98 percent of value within hours of designation
              • harm less than face value since large transfers were internal
              • vendor and manual rescreening on every list update
              • cooperation
              • no prior penalty notice or FOV
              Aggravating
              • had reason to know the vendor rescreened existing accounts only monthly
              • two weeks of operation post-designation risked asset flight

              Note: Finding of Violation in lieu of penalty.

              Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

              Jul 15, 2022Settlement$430,500

              American Express National Bank

              Banking (card issuer) · Narcotics program · 214 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: no

              Alerts cleared wrongly

              After a supplemental cardholder was designated under the Kingpin program, Amex's screening produced a high-confidence alert matching name, date of birth and Venezuelan ID, but an analyst closed it without the required second-level review. When AML later suspended the account, a customer care agent lifted the suspension because no sanctions note had been entered, and a wrong suspension code allowed seven more transactions.

              “erroneously closed by an operations analyst responsible for conducting the initial review of the alert despite a match against multiple data elements”
              Mitigating and aggravating factors
              Mitigating
              • prompt cooperation
              • automated second-level review reporting, centralized suspension process with a sanctions-only code, training, sanctions referral flag in AML cases
              • continued compliance commitments
              Aggravating
              • large sophisticated institution
              • $155,189 benefit to an account tied to an SDN designated for drug trafficking and money laundering

              Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

              Apr 25, 2022Settlement$6,131,855

              Toll Holdings Limited

              Logistics and freight (freight forwarding) · North Korea and Iran and Syria and SDN/counterterrorism and WMD programs · 2,958 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

              Third-party or vendor paymentsNo compliance programLegacy or unintegrated systemFacilitation

              Toll's 23 overseas units sent or received 2,958 payments through US banks for shipments to, from or through North Korea, Iran and Syria and for Mahan Air and Hafiz Darya Shipping, often as parts of larger invoices settling with affiliates, suppliers and customers. Rapid acquisitions left almost 600 invoicing and payment systems and no controls, and after a bank flagged a Syria payment a treasury employee told affiliates to leave sanctioned country names off invoices.

              “instructing employees in Toll’s United Arab Emirates and South Korea affiliates to avoid including the names of sanctioned jurisdictions on invoices”
              Mitigating and aggravating factors
              Mitigating
              • no penalty notice or Finding of Violation in prior five years
              • voluntary self-disclosure, forensic analysis and organized cooperation
              • extensive remediation including root cause risk mapping and targeted controls
              Aggravating
              • reckless disregard over six years despite a compliance policy and repeated bank warnings
              • knew or had reason to know from bank concerns
              • 14 percent of violations involved terrorism or WMD designees
              • major global freight forwarder with 1,200 agents and offices
              • did not act promptly after May 2015 bank engagement

              Source: OFAC enforcement release (PDF), Australia; read Nov. 1, 2026.

              Apr 21, 2022Settlement$141,442

              Newmont Corporation (for Newmont Suriname)

              Other: mining · Cuba program · 4 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

              Third-party or vendor paymentsScreening skipped data fieldsCustomer or counterparty due diligence

              Newmont Suriname's explosives distributor filled four orders with Cuban-origin explosives from ULAEX, and bills of lading on all four named ULAEX and its Cuban address; an untrained assistant manager handled the first and the distributor kept sourcing from Cuba after assurances it would stop. Purchase orders carried no embargoed-origin clause and no country-of-origin information was requested.

              “Newmont Suriname’s purchase orders did not contain express statements that no items provided to Newmont Suriname may originate from embargoed jurisdictions”
              Mitigating and aggravating factors
              Mitigating
              • no penalty notice or Finding of Violation in prior five years
              • not significant relative to annual volume
              • voluntary self-disclosure and tolling
              • training on embargoes, denied persons screening and licensing, plus purchase order changes
              Aggravating
              • failed minimal caution, should have known from readily available information
              • large sophisticated global gold producer

              Source: OFAC enforcement release (PDF), United States (Suriname subsidiary); read Nov. 1, 2026.

              Apr 21, 2022Settlement$45,908

              Chisu International Corporation

              Other: explosives distributor · Cuba program · 4 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

              Third-party or vendor paymentsNo compliance programScreening skipped data fields

              A small Florida company processed purchase orders and invoices for four shipments of explosives bought through a non-US distributor from ULAEX, a Cuban military-linked joint venture, for a US mining customer in Suriname. The bills of lading named ULAEX, a Villa Clara address and the port of Cienfuegos, but the company had no compliance program and did not know indirect dealings in Cuban goods were barred.

              “the bill of lading associated with the first transaction clearly identified ULAEX as the exporter of the goods”
              Mitigating and aggravating factors
              Mitigating
              • small company overseen by a single individual
              • no penalty notice or Finding of Violation in prior five years
              • timely information and tolling agreement
              Aggravating
              • failed minimal caution in procuring Cuban-origin explosives
              • actual knowledge it was financing Cuban-origin goods
              • procured from an entity under Cuban military control

              Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

              Apr 1, 2022Settlement$78,750

              S&P Global, Inc. (for Petroleum Industry Research Associates)

              Other: business information and analytics · Ukraine/Russia program · 4 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

              Alerts cleared wronglyCustomer or counterparty due diligence

              PIRA, later acquired by S&P Global, reissued and re-dated an $82,500 Rosneft invoice four times over two years after banks rejected payments citing sanctions, so that collecting the past-due amount became dealing in prohibited new debt of an SSI entity. Managers knew the bank might see old-invoice payments as extending credit.

              “reissued and re-dated four invoices to extend the payment date of invoices far beyond the authorized debt tenor”
              Mitigating and aggravating factors
              Mitigating

              None stated in the release.

              Aggravating
              • failed minimal caution in re-dating invoices far beyond the authorized tenor knowing it could violate sanctions
              • PIRA and S&P Global managers aware and involved
              • sophisticated entities

              Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

              Jan 11, 2022Settlement$5,228,298

              Sojitz (Hong Kong) Limited

              Other: commodity trading · Iran program · 60 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

              Third-party or vendor paymentsFacilitation

              Sojitz HK employees bought 64,000 tons of Iranian-origin polyethylene from a Thai supplier for Chinese buyers and paid $75.6 million in 60 USD wires through US correspondent banks, after being told repeatedly they could not make USD payments for Iran business. They had the supplier omit Iran from bills of lading and told management the resin was made in Thailand.

              “requesting that the Thai supplier make no reference to Iran on the bills of lading”
              Mitigating and aggravating factors
              Mitigating
              • compliance personnel repeatedly instructed employees not to make USD payments for Iran business
              • senior management and compliance unaware because of concealment

              The release lists further factors; see the source.

              Aggravating
              • employees omitted Iranian origin from all documents for two years despite explicit instructions
              • a mid-level manager had actual knowledge
              • significant benefit to Iran's petrochemical sector
              • sophisticated trading company

              Source: OFAC enforcement release (PDF), Hong Kong; read Nov. 1, 2026.

              Jan 3, 2022Settlement$91,172

              Airbnb Payments, Inc.

              Payments (money services business for a travel platform) · Cuba program · 6,584 apparent violations · not an AP or vendor case · self-disclosed: yes · egregious: no

              Geolocation or IP data ignoredLegacy or unintegrated systemCustomer or counterparty due diligence

              Airbnb Payments processed Cuba lodging payments for guests traveling outside the 12 authorized categories and failed to keep required records for Experiences because an older mobile app version could not capture travel-reason attestations. The Cuba launch in 2015 outpaced the company's ability to manage sanctions risk on its platform.

              “The older version of the application did not maintain complete functionality for Guests to make an attestation regarding their reason for travel to Cuba”
              Mitigating and aggravating factors
              Mitigating
              • no penalty notice or Finding of Violation in prior five years
              • proactive program review and voluntary reporting, substantial cooperation
              • IP blocking regime, collection of country of residence and payment instrument data, other commitments
              Aggravating
              • violations followed the 2015 Cuba policy change and undermined the retained restrictions
              • large sophisticated technology company

              Note: violation count is extrapolated from sampling: 3,464 Stays, 3,076 Experiences recordkeeping failures, 44 confirmed non-US person transactions.

              Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

              Dec 23, 2021Settlement$105,239

              TD Bank, N.A. (North Korea mission accounts)

              Banking · North Korea program · 1,479 apparent violations · not an AP or vendor case · self-disclosed: yes · egregious: no

              Screening skipped data fieldsCustomer or counterparty due diligenceLegacy or unintegrated system

              TD Bank opened nine accounts for five employees of the North Korean UN mission who presented North Korean passports, because its vendor PEP list omitted government employees of sanctioned countries and staff entered the citizenship as Korea, South Korea or left it blank. It processed 1,479 transactions without the specific license the general license requires.

              “TDBNA employees often misidentified North Korea (referring to it as Korea or South Korea or using a country code meant for South Korea)”
              Mitigating and aggravating factors
              Mitigating
              • no managers or supervisors had actual knowledge
              • transactions likely licensable
              • enhanced controls for officials of sanctioned countries, escalation procedures and training
              • voluntary self-disclosure and prompt cooperation
              Aggravating
              • failed due caution across multiple screening breakdowns for over a year
              • had reason to know from the passports
              • large sophisticated global institution

              Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

              Dec 23, 2021Settlement$9,766

              TD Bank, N.A. (SDN customer accounts)

              Banking · Narcotics program · 145 apparent violations · not an AP or vendor case · self-disclosed: yes · egregious: no

              Alerts cleared wronglyName matching false negative

              A Miami branch opened two accounts for a person on the SDN List, and reviewers dismissed four high-confidence alerts over four years because the middle name differed, despite first name, last name and date of birth matches and a procedure requiring escalation. After the accounts were finally blocked, the fraud unit credited one and reopened it for a few days.

              “the reviewer dismissed the alert because there was “no match on full name DOB and geographical location.””
              Mitigating and aggravating factors
              Mitigating

              None stated in the release.

              Aggravating
              • incorrectly adjudicated high-confidence alerts four times over four years
              • analysts contravened escalation procedures

              Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

              Dec 8, 2021Settlement$133,860

              An Individual (US person receiving Iranian company payments)

              Other: individual · Iran program · 4 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: yes

              FacilitationThird-party or vendor payments

              A US individual received four payments totaling $133,860 into a personal US bank account on behalf of an Iranian cement company for clinker sold to a third-country project, and relayed shipping details for a relative at the company. OFAC had earlier denied the person a license and spelled out the Iran prohibitions.

              “received, four payments totaling $133,860 into his personal bank account in the United States on behalf of an Iranian cement company”
              Mitigating and aggravating factors
              Mitigating
              • no penalty notice, Finding of Violation or cautionary letter in prior five years
              • natural person with minimal benefit and financial difficulties
              Aggravating
              • willful or reckless receipt of payments for an Iranian company
              • aware and actively participated
              • enabled an Iranian company to evade sanctions

              Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

              Nov 9, 2021Finding of violationno penalty

              Mashreqbank psc

              Banking · Sudan program · 1,760 apparent violations · not an AP or vendor case · self-disclosed: not stated · egregious: not stated

              Screening skipped data fieldsFacilitation

              Mashreq's London branch sent 1,760 USD payments through US banks for Sudanese banks' offshore accounts without populating the optional originating institution field in MT202 messages, so US correspondents could not see the Sudanese originator. The bank had closed Sudanese USD accounts and overhauled compliance years before the investigation.

              “Mashreq did not populate optional field 52 (originating institution) in the MT202 payment messages”
              Mitigating and aggravating factors
              Mitigating
              • substantial cooperation including a retroactive statute of limitations waiver
              • no penalty notice or Finding of Violation in prior five years
              • discontinued the activity years earlier and extensively remediated, including automated screening and payment transparency requirements
              Aggravating
              • 1,760 transactions over several years
              • reckless payment practices that hid sanctioned parties
              • senior branch employees had actual knowledge
              • internal controls did not ensure compliance

              Note: Finding of Violation in lieu of penalty, partly because the bank signed a retroactive statute of limitations waiver; part of a global settlement with NYDFS and the Federal Reserve.

              Source: OFAC enforcement release (PDF), United Arab Emirates; read Nov. 1, 2026.

              Sep 27, 2021Settlement$160,000

              Schlumberger Rod Lift, Inc. (now Lufkin Rod Lift)

              Manufacturing and trade (oilfield equipment) · Sudan program · 1 apparent violation · AP or vendor relevant · self-disclosed: no · egregious: no

              Facilitation

              Three US employees, including a vice president and operations manager, helped arrange a sale of oilfield equipment from a Canadian Schlumberger subsidiary to a Chinese joint venture for delivery to Sudan, after being told Sudan was sanctioned and attending a six-hour training with a Sudan facilitation case study. The conduct followed a 2015 Finding of Violation and DOJ plea involving Sudan.

              “facilitated the sale and shipment of oilfield equipment from a Canadian subsidiary of Schlumberger to a Chinese joint venture”
              Mitigating and aggravating factors
              Mitigating
              • full cooperation including documentation and tolling
              • removal of personnel and compliance enhancements
              Aggravating
              • employees explicitly told Sudan was sanctioned and trained on it
              • knew goods would go to Sudan
              • shortly after a 2015 Finding of Violation and during a DOJ plea agreement

              Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

              Sep 27, 2021Settlement$1,423,766

              Cameron International Corporation

              Manufacturing and trade (oil and gas equipment) · Ukraine/Russia program · 5 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

              FacilitationScreening skipped data fieldsCustomer or counterparty due diligence

              Four US senior managers at Cameron approved five contracts for its Romanian subsidiary to supply goods to Gazprom-Neft Shelf's Arctic offshore platform, a Directive 4 restricted project, leading to 111 shipments. Cameron's Russia transaction review form did not flag that US-person involvement in a foreign subsidiary's deal could itself be prohibited.

              “the form did not indicate that U.S.-person involvement in the activities of Cameron’s foreign subsidiaries could have fallen within the applicable prohibitions”
              Mitigating and aggravating factors
              Mitigating
              • meaningful corrective actions including a recusal acknowledgement system for US persons on Russia-related activity
              Aggravating
              • US senior managers knew approvals were for Gazprom-Neft Shelf Arctic oil work
              • real economic benefit contrary to Directive 4 objectives
              • large sophisticated firm aware of sanctions risk

              Note: notifications submitted but not treated as a voluntary self-disclosure; no mitigation from base penalty.

              Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

              Sep 9, 2021Settlement$189,483

              NewTek, Inc.

              Manufacturing and trade (video production hardware and software) · Iran program · 52 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

              Third-party or vendor paymentsNo compliance programCustomer or counterparty due diligence

              NewTek exported 49 products to French and Dubai distributors whose territories explicitly included Iran, knowing they went to an Iranian reseller that sold three to IRIB, an SDN, and gave the distributor sales credits for Iranian sales. It had no sanctions policies or training and believed indirect sales through a third-country distributor were permitted.

              “specifically authorized the distribution of NewTek products in a list of countries comprising the Middle East sales territory, which explicitly included Iran”
              Mitigating and aggravating factors
              Mitigating

                The release lists further factors; see the source.

                Aggravating
                • reckless disregard in authorizing distribution in Iran on a mistaken understanding
                • actual knowledge at all levels including executive board members
                • harm by facilitating sales to Iran including an SDN

                Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                Aug 27, 2021Settlement$862,318

                First Bank SA and JC Flowers & Co.

                Banking · Iran and Syria programs · 98 apparent violations · not an AP or vendor case · self-disclosed: yes · egregious: no

                Screening skipped data fieldsNo compliance program

                First Bank processed 70 USD payments through US banks where trade documents showed Iranian or Syrian end users or importers, and after JC Flowers bought a majority stake it processed 28 Euro payments for Iranian parties outside the US system. Its procedures did not consider that trade finance documents could reveal a sanctions nexus.

                “indirectly exporting financial services through the U.S. financial system to sanctioned parties or comprehensively sanctioned jurisdictions noted in underlying trade finance and shipping documents”
                Mitigating and aggravating factors
                Mitigating
                • no penalty notice or Finding of Violation in prior five years
                • historical lookback and tolling
                • updated screening tool and other remedial measures after change of ownership
                Aggravating
                • reckless failure to implement controls for US-nexus payments and post-acquisition status
                • actual knowledge or reason to know from trade documents
                • $3.6 million economic benefit over at least three years

                Source: OFAC enforcement release (PDF), Romania (US-owned); read Nov. 1, 2026.

                Aug 26, 2021Settlement$2,329,991

                Bank of China (UK) Limited

                Banking · Sudan program · 111 apparent violations · not an AP or vendor case · self-disclosed: yes · egregious: no

                Screening skipped data fieldsCustomer or counterparty due diligence

                BOC UK processed 111 USD payments worth $40.6 million through US banks for two customers tied to Sudan, one with a Sudanese branch as signatory and one registered in Sudan per its KYC file. The customer database had no Sudan reference in name or address fields, so SWIFT messages carried none and staff did not escalate what the documents showed.

                “BOC UK’s internal customer database did not include reference to Sudan in the name or address fields of either customer”
                Mitigating and aggravating factors
                Mitigating
                • no prior sanctions history
                • self-identified through a lookback and tolled the statute
                • executive compliance committee, annual sanctions risk assessment, centralized due diligence, training
                Aggravating
                • reckless processing despite account information showing the Sudan connection, contrary to its own procedures
                • personnel aware the payments related to Sudan
                • $40.6 million benefit over a year and a half
                • sophisticated international institution

                Source: OFAC enforcement release (PDF), United Kingdom; read Nov. 1, 2026.

                Jul 23, 2021Settlement$1,385,901

                Payoneer Inc.

                Payments (online money transmitter and prepaid access) · Crimea and Iran and Sudan and Syria and Zimbabwe and WMD programs · 2,220 apparent violations · AP or vendor relevant · self-disclosed: partial · egregious: no

                Name matching false negativeScreening skipped data fieldsAlerts cleared wronglyGeolocation or IP data ignored

                Payoneer processed 2,201 commercial payments for parties in Crimea, Iran, Sudan and Syria and 19 for SDNs because weak matching let close SDN matches through, BICs were not screened, pended payments were auto-released during backlogs, and billing, shipping and IP addresses in sanctioned locations were not flagged. Its testing and auditing never caught the gaps.

                “during backlog periods, allowing flagged and pended payments to be automatically released without review”
                Mitigating and aggravating factors
                Mitigating
                • senior management quickly self-disclosed the SDN-related violations and cooperated
                • no penalty notice or Finding of Violation in prior five years
                • replaced CCO, retrained staff, screening of aliases, BICs, addresses and IP data, automatic manual review of SDN matches
                Aggravating
                • failed minimal caution for years allowing SDNs and sanctioned-location users to transact
                • had reason to know location from billing, shipping, IP addresses and ID copies
                • harm to six sanctions programs

                Note: 19 SDN-related violations self-disclosed, 2,201 not.

                Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                Jul 19, 2021Settlement$415,695

                Alfa Laval Middle East Ltd.

                Manufacturing and trade (fluid handling equipment distribution) · Iran program · violation count not stated · AP or vendor relevant · self-disclosed: no · egregious: yes

                FacilitationThird-party or vendor payments

                Alfa Laval's Dubai office, with the Iranian affiliate, an Iranian distributor and a Dubai front company, planned to buy US-made Gamajet units from the US affiliate by naming the Dubai company as end user, and the Dubai company paid AL Middle East $18,585 for goods destined for Iran. The settlement was credited against a parallel BIS penalty.

                “the Dubai company would be falsely named as the end-user on export documents”
                Mitigating and aggravating factors
                Mitigating
                • no penalty notice or Finding of Violation in prior five years
                • internal investigation by outside counsel, three terminations, enhanced Iran screening, training
                • substantial cooperation
                Aggravating
                • willful conspiracy that hid the end user from the US affiliate
                • sales manager formed the conspiracy and managers at AL Middle East and AL Iran knew
                • economic benefit to Iran's energy sector

                Source: OFAC enforcement release (PDF), United Arab Emirates; read Nov. 1, 2026.

                Jul 19, 2021Settlement$16,875

                Alfa Laval Inc. (for Alfa Laval Tank, Inc.)

                Manufacturing and trade (tank cleaning equipment) · Iran program · 3 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

                FacilitationThird-party or vendor paymentsCustomer or counterparty due diligence

                After an Iranian distributor asked to buy Gamajet tank cleaners, AL Tank's portfolio manager referred the inquiry to the Dubai affiliate, which then ordered the units for a Dubai front company that re-exported them to Iran. AL Tank had seen an email subject line naming the Iranian buyer and a quotation listing Iran as end user before shipping.

                “The subject line of the email stated “Gamajet for Alborz Pakhsh Parnia Company IRAN.””
                Mitigating and aggravating factors
                Mitigating

                  The release lists further factors; see the source.

                  Aggravating
                  • reckless disregard of numerous warning signs that the end user was in Iran
                  • referral of an Iran opportunity to a foreign affiliate that formed a conspiracy

                  Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                  Apr 29, 2021Settlement$2,132,174

                  SAP SE

                  Software · Iran program · 190 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

                  Geolocation or IP data ignoredThird-party or vendor paymentsCustomer or counterparty due diligenceLegacy or unintegrated system

                  SAP resellers in Turkey, the UAE, Germany and Malaysia sold licenses and maintenance to pass-through companies that served Iranian users, with software delivered from US servers, and SAP's US cloud subsidiaries sold subscriptions used in Iran. Internal audits from 2006 onward had flagged that SAP did not screen download IP addresses, but geolocation blocking was not implemented until 2015 and partner due diligence missed public Iran ties.

                  “SAP failed to implement the recommended geolocation IP address screening until 2015”
                  Mitigating and aggravating factors
                  Mitigating
                  • no prior OFAC sanctions history

                  The release lists further factors; see the source.

                  Aggravating
                  • ignored eight years of internal audit findings, compliance warnings and whistleblower claims
                  • compliance program not commensurate with size, no timely IP geolocation screening, inadequate partner due diligence, standalone cloud units
                  • direct knowledge or reason to know, some managers facilitated sales
                  • $3.9 million of enterprise software to Iranian businesses
                  • sophisticated company with many subsidiaries

                  Note: OFAC amount deemed satisfied by larger DOJ and BIS payments.

                  Source: OFAC enforcement release (PDF), Germany; read Nov. 1, 2026.

                  Apr 29, 2021Settlement$34,329

                  MoneyGram Payment Systems, Inc.

                  Payments (money transmitter) · Narcotics and Syria and DRC and Central African Republic and WMD programs · 359 apparent violations · not an AP or vendor case · self-disclosed: yes · egregious: no

                  No screening performedName matching false negativeLegacy or unintegrated systemAlerts cleared wrongly

                  MoneyGram did not screen federal inmates receiving commissary payments against the SDN List for almost two years, believing screening was not expected under the Bureau of Prisons program, and after it started, fuzzy logic and technology failures still let payments to about 40 SDNs through. Analysts also wrongly treated some Syria-related commercial payments as personal remittances.

                  “MoneyGram retired its legacy screening system and launched a new system”
                  Mitigating and aggravating factors
                  Mitigating
                  • most transactions likely licensable
                  • no penalty notice or Finding of Violation in prior five years
                  • cooperation
                  • found through its own compliance improvement program and self-disclosed
                  • retired legacy screening system, daily batch screening of inmates, inmate names in transaction data, 128 more compliance staff
                  Aggravating
                  • knew blocked persons could be among inmates but did not screen because of a misunderstanding
                  • large sophisticated institution

                  Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                  Apr 19, 2021Settlement$435,003

                  Alliance Steel, Inc.

                  Manufacturing and trade (prefabricated steel structures) · Iran program · 61 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

                  Third-party or vendor paymentsNo compliance programNo screening performed

                  An Oklahoma steel building maker outsourced engineering work for five years to an Iranian firm owned by its vice president of engineering's brother, paying about $1.45 million by check. At least 12 senior managers knew the subcontractor was Iranian and approved the invoices, but the company, which otherwise did no international business, had no sanctions awareness.

                  “numerous senior Alliance officials were involved in the process of approving each transaction and issuing checks to the Iranian engineering company”
                  Mitigating and aggravating factors
                  Mitigating
                  • no penalty notice or Finding of Violation in prior five years
                  • voluntary self-disclosure and organized cooperation
                  • terminated the work and the employee, adopted export compliance policy requiring president's approval of international contracts
                  Aggravating
                  • failed basic due diligence on its only international relationship
                  • senior management knew and approved invoices and checks
                  • over $1 million benefit to Iran over five years

                  Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                  Mar 26, 2021Settlement$950,000

                  Nordgas S.r.l.

                  Manufacturing and trade (gas boiler components) · Iran program · 27 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: yes

                  Third-party or vendor paymentsFacilitation

                  Nordgas bought air pressure switches from a US supplier that had told it Iranian end users were off limits, claimed its Italian affiliate was the end user, used code words for Iran and asked the supplier to remove 'Made in USA' labels, then re-exported 27 shipments to up to ten Iranian customers. The US company caught the last shipment and had it returned.

                  “requested that the U.S. company remove the term “Made in USA” from the switches to disguise their origin”
                  Mitigating and aggravating factors
                  Mitigating
                  • no penalty notice or Finding of Violation in prior five years
                  • ceased shipments, implemented a compliance program and agreed to five years of annual reports
                  • detailed cooperation
                  Aggravating
                  • willful re-exports after being told they were prohibited
                  • management had reason to know and failed oversight
                  • over $2.5 million of US goods diverted to Iran

                  Note: $650,000 of the settlement suspended pending compliance commitments.

                  Source: OFAC enforcement release (PDF), Italy; read Nov. 1, 2026.

                  Mar 15, 2021Settlement$216,464

                  UniControl, Inc.

                  Manufacturing and trade (process controls and pressure switches) · Iran program · 21 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

                  Third-party or vendor paymentsCustomer or counterparty due diligence

                  UniControl shipped 21 lots of air pressure switches to two European distributors that re-exported them to Iran, ignoring warning signs such as a sales representative agreement that listed Iran as a resale territory, meetings with Iranian nationals at trade shows and a request to remove the 'Made in USA' label. It shipped the final two lots with actual knowledge of the Iranian end user.

                  “explicitly listed Iran as a country to which the European company could re-sell UniControl goods”
                  Mitigating and aggravating factors
                  Mitigating
                  • modest-sized company with no prior sanctions history
                  • ceased shipments and asked for returns at disclosure

                  The release lists further factors; see the source.

                  Aggravating
                  • failed to follow up on multiple warning signs for 19 shipments
                  • senior leadership aware or should have been
                  • actual knowledge for the final two shipments, including the President

                  Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                  Feb 18, 2021Settlement$507,375

                  BitPay, Inc.

                  Fintech and digital assets (digital currency payment processor) · Crimea and Cuba and North Korea and Iran and Sudan and Syria programs · 2,102 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

                  Geolocation or IP data ignoredScreening skipped data fields

                  BitPay screened its merchant customers but not the buyers paying them, so people in Crimea, Cuba, North Korea, Iran, Sudan and Syria made 2,102 purchases worth about $129,000 through its platform. It held buyer names, addresses and, from late 2017, IP addresses but did not analyze them for sanctions.

                  “BitPay failed to screen location data that it obtained about its merchants’ buyers”
                  Mitigating and aggravating factors
                  Mitigating
                  • screened and performed due diligence on merchants since 2013, formal program in 2014
                  • training prohibited merchant signups from sanctioned jurisdictions
                  • small business with no prior penalty notice or Finding of Violation
                  • cooperation
                  • remedial measures including blocking sanctioned-jurisdiction IP addresses
                  Aggravating
                  • failed due caution for about five years despite having information to screen buyers
                  • $128,583 benefit to individuals in sanctioned jurisdictions

                  Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                  Jan 14, 2021Settlement$1,016,000

                  PT Bukit Muria Jaya

                  Manufacturing and trade (cigarette paper) · North Korea program · 28 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

                  FacilitationCustomer or counterparty due diligenceThird-party or vendor payments

                  BMJ sold cigarette paper to a Chinese intermediary buying for a designated North Korean trading company operating under an alias, replaced DPRK names on invoices and bills of lading with third-country intermediaries at customers' request, and had buyers pay into its USD account at a non-US bank. That routed 28 wires through US banks.

                  “all trading companies or agents who purchase goods on behalf of other end-users sign an anti-diversion agreement”
                  Mitigating and aggravating factors
                  Mitigating
                  • no penalty notice or Finding of Violation in prior five years and small share of business
                  • detailed cooperation and ongoing cooperation commitment
                  • new compliance head, third-party screening service, written policy, KYC escalation, anti-diversion agreements for trading agents
                  Aggravating
                  • reckless disregard in directing DPRK payments to a USD account
                  • management knew of DPRK sales and document alterations
                  • significant harm by causing US persons to benefit the DPRK and an SDN

                  Note: OFAC amount deemed satisfied by a larger DOJ payment.

                  Source: OFAC enforcement release (PDF), Indonesia; read Nov. 1, 2026.

                  Jan 4, 2021Settlement$8,572,500

                  Union de Banques Arabes et Françaises (UBAF)

                  Banking · Syria and WMD programs · 127 apparent violations · not an AP or vendor case · self-disclosed: yes · egregious: no

                  FacilitationScreening skipped data fields

                  UBAF kept USD accounts for sanctioned Syrian banks and moved their money through internal book transfers and FX swaps with non-sanctioned clients that were then mirrored by USD transfers through US banks, plus back-to-back letters of credit. It believed avoiding direct USD clearing for sanctioned parties was enough.

                  “it incorrectly believed that avoiding direct USD clearing on behalf of sanctioned parties was sufficient”
                  Mitigating and aggravating factors
                  Mitigating
                  • most violations in late 2011 shortly after E.O. 13582
                  • had a compliance program
                  • voluntary self-disclosure and tolling
                  • no penalty notice or Finding of Violation in prior five years
                  • substantial investment in compliance improvements
                  Aggravating
                  • reckless continuation of USD services to sanctioned Syrian parties after August 2011
                  • management had actual knowledge
                  • significant economic benefit to sanctioned parties

                  Note: release text gives settlement as both $8,572,500 and $8,527,500; year table shows 8,572,500.

                  Source: OFAC enforcement release (PDF), France; read Nov. 1, 2026.

                  Dec 30, 2020Settlement$98,830

                  BitGo, Inc.

                  Fintech and digital assets (digital asset wallet services) · Crimea and Cuba and Iran and Sudan and Syria programs · 183 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: no

                  Geolocation or IP data ignoredCustomer or counterparty due diligenceNo compliance program

                  BitGo let users in Crimea, Cuba, Iran, Sudan and Syria open hot wallet accounts and make 183 transactions worth $9,128 while it collected their IP addresses for security but not for sanctions. Until 2018 signup required only a name and email, and afterward it relied on self-attested location.

                  “BitGo, however, did not use this IP address information for sanctions compliance purposes”
                  Mitigating and aggravating factors
                  Mitigating
                  • relatively small company with no prior penalty notice or Finding of Violation
                  • cooperation
                  • Chief Compliance Officer hired, new OFAC policy, IP blocking and compliance commitments
                  Aggravating
                  • failed to implement risk-based controls to keep sanctioned-jurisdiction users off the platform
                  • had reason to know from IP data collected for security

                  Note: release text states settlement amount of $93,830 in one place and $98,830 in the headline; year table shows 98,830.

                  Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                  Dec 28, 2020Settlement$653,347

                  The National Commercial Bank

                  Banking · Sudan and Syria programs · 13 apparent violations · not an AP or vendor case · self-disclosed: partial · egregious: no

                  Screening skipped data fields

                  NCB processed 13 USD transactions worth $5.9 million through the US where Sudanese or Syrian counterparties benefited or goods originated in or transited those countries, even though none of those parties were its customers. The conduct began as the bank was upgrading its screening and compliance controls.

                  “None of the Sudanese or Syrian parties was a customer of NCB”
                  Mitigating and aggravating factors
                  Mitigating
                  • no willful or reckless conduct
                  • no prior sanctions history
                  • extensive transaction review and tolling
                  • most Syria violations shortly after the prohibitions
                  • replaced board and executives, new screening software, transparency policies, screening of all payments
                  Aggravating
                  • substantial economic benefit to sanctioned parties over years
                  • large sophisticated financial institution

                  Note: eight Syria-related violations self-disclosed, five Sudan-related not.

                  Source: OFAC enforcement release (PDF), Saudi Arabia; read Nov. 1, 2026.

                  Oct 20, 2020Settlement$4,144,651

                  Berkshire Hathaway Inc. (for Iscar Kesici Takim, Turkey)

                  Manufacturing and trade (cutting tools) · Iran program · 144 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: yes

                  Third-party or vendor paymentsFacilitation

                  Managers at Berkshire's Turkish subsidiary Iscar Turkey sold cutting tools through two Turkish distributors to an Iranian distributor in 144 orders, took cash Euro payments, used private email, entered false end-customer names and gave fraudulent compliance assurances. Other Berkshire subsidiaries supplied goods used to fill the Iran orders.

                  “the Iranian distributor made payments in cash and denominated in Euros”
                  Mitigating and aggravating factors
                  Mitigating
                  • voluntary self-disclosure
                  • prompt responses and cooperation
                  • three tolling agreements
                  • replaced complicit personnel and enhanced foreign subsidiary compliance
                  • no penalty notice or Finding of Violation in prior five years
                  Aggravating
                  • management willfully engaged knowing it was prohibited
                  • other Berkshire subsidiaries knew or had reason to know products were for Iran
                  • senior management intentionally concealed dealings
                  • three-year pattern
                  • sought a foothold in Iran while prohibited
                  • undermined US leverage in Iran negotiations

                  Source: OFAC enforcement release (PDF), United States (Turkish subsidiary); read Nov. 1, 2026.

                  Oct 1, 2020Settlement$5,864,860

                  Generali Global Assistance, Inc.

                  Insurance (travel assistance and claims services) · Cuba program · 2,593 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: yes

                  FacilitationScreening skipped data fieldsThird-party or vendor payments

                  GGA, servicing Canadian travel insurers, paid Cuba-related claims to Canadian travelers directly and routed payments to Cuban medical providers through a Canadian affiliate that it then reimbursed, a referral process written into its procedures manual and approved by its CEO. Its screening checked SDN names but not sanctioned countries.

                  “GGA’s procedures failed to require screening for countries and regions subject to OFAC prohibitions”
                  Mitigating and aggravating factors
                  Mitigating
                  • Cuba rules later authorized some conduct and transaction value was low
                  • no prior administrative actions in five years
                  • enhanced policies, formal compliance structure and training
                  • voluntary self-disclosure and tolling
                  • compliance commitments
                  Aggravating
                  • recklessness in formalizing indirect payments it knew could not be made directly
                  • CEO-approved procedure, so awareness
                  • part of a large sophisticated global organization

                  Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                  Sep 24, 2020Settlement$473,157

                  Keysight Technologies Inc. (for Anite Finland Oy)

                  Manufacturing and trade (test and measurement equipment) · Iran program · 6 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: yes

                  FacilitationThird-party or vendor payments

                  After Keysight acquired Anite and ordered an end to Iran sales, Anite's regional director and colleagues, with the EMEA vice president's knowledge, shipped six orders of equipment with US-controlled content to Iran and hid it, in one case editing an email to replace Iran with the UAE. Keysight investigated, fired them and self-disclosed.

                  “the Regional Director altered the email correspondence to reference the United Arab Emirates in place of Iran”
                  Mitigating and aggravating factors
                  Mitigating
                  • no penalty notice or Finding of Violation in prior five years
                  • full cooperation and tolling
                  • internal investigation, terminations and halted transactions
                  • full integration of Anite and enhanced compliance
                  Aggravating
                  • willful scheme to circumvent Keysight's directive
                  • senior branch and sales managers participated
                  • significant harm given value and concealment

                  Source: OFAC enforcement release (PDF), United States (Finnish subsidiary); read Nov. 1, 2026.

                  Sep 17, 2020Settlement$894,111

                  Comtech Telecommunications Corp. and Comtech EF Data Corp.

                  Manufacturing and trade (satellite communications equipment) · Sudan program · 4 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: yes

                  Alerts cleared wronglyFacilitationThird-party or vendor payments

                  EF Data sold warrantied satellite equipment to a Canadian integrator knowing the end user was the Sudan Civil Aviation Authority, after its credit manager raised the issue, the consignee document named SCAA and its screening software alerted on Sudan. Its export compliance official tried to shift OFAC obligations to the Canadian buyer, and support continued while a license application was pending and later denied.

                  “EF Data received yet another warning from its third-party screening software alerting EF Data to OFAC export restrictions for Sudan”
                  Mitigating and aggravating factors
                  Mitigating

                    The release lists further factors; see the source.

                    Aggravating
                    • reckless approval of warranty services while a license was pending
                    • ignored screening software alert
                    • managers and compliance personnel knew the end user was SCAA
                    • economic benefit to the Government of Sudan
                    • sophisticated supplier experienced with OFAC
                    • shifting explanations and a manipulated email in subpoena response

                    Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                    Sep 9, 2020Settlement$425,600

                    Deutsche Bank Trust Company Americas (Krayinvestbank payments)

                    Banking · Crimea program · 61 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: no

                    Screening skipped data fieldsName matching false negative

                    DBTCA processed 61 payments to accounts at Krayinvestbank, an SDN bank, because it had not loaded the bank's SWIFT BIC into its filter and the filter was set to flag only exact matches, so near-identical name and address matches went straight through. A 2013 settlement had involved the same BIC omission.

                    “DBTCA’s filter was calibrated in such a way that only a payment with an exact SDN List match would trigger manual review”
                    Mitigating and aggravating factors
                    Mitigating
                    • no willful intent or reckless disregard
                    • no supervisory awareness
                    • small share of volume
                    • promptly changed BIC loading procedures
                    • prompt and well-organized cooperation
                    Aggravating
                    • failed to follow internal procedures by omitting the SWIFT BIC
                    • should have known because each payment carried the BIC
                    • economic benefit to a designated bank
                    • large sophisticated institution
                    • 2013 settlement for almost identical conduct

                    Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                    Sep 9, 2020Settlement$157,500

                    Deutsche Bank Trust Company Americas (IPP Oil Products payment)

                    Banking · Ukraine/Russia program · 1 apparent violation · not an AP or vendor case · self-disclosed: no · egregious: no

                    Alerts cleared wrongly50 Percent Rule missed

                    DBTCA processed a $28.8 million fuel oil payment a week after IPP Oil Products (Cyprus) was designated, relying on verbal assurances from a non-customer's US counsel that title had passed before designation. Senior anti-financial crime staff accepted the assurance within an hour and did not independently corroborate it.

                    “DBTCA did not conduct further due diligence to attempt to independently corroborate the statements of U.S. counsel”
                    Mitigating and aggravating factors
                    Mitigating

                    None stated in the release.

                    Aggravating
                    • senior anti-financial crime managers and counsel failed to exercise minimal caution
                    • actual knowledge of the conduct

                    The release lists further factors; see the source.

                    Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                    Aug 11, 2020Settlement$5,000

                    An Individual (US Army civilian employee)

                    Other: individual · Narcotics program · 24 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: yes

                    A US Army civilian at the Bogota embassy bought gifts, meals and hotel rooms for a designated narcotics trafficker during a personal relationship, knowing of the designation. The transaction value was about $3,349.

                    “U.S. Person-1 was aware that they were having a personal relationship with a specially designated narcotics trafficker”
                    Mitigating and aggravating factors
                    Mitigating
                    • relieved of duties and disciplined by the Army
                    • natural person without sanctions experience
                    • personal one-time-use goods
                    • cooperation
                    Aggravating
                    • failed to use available OFAC resources
                    • actual knowledge
                    • perception of impropriety during a delisting request
                    • national security position

                    Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                    Jul 28, 2020Settlement$824,314

                    Whitford Worldwide Company, LLC

                    Manufacturing and trade (cookware coatings) · Iran program · 74 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

                    FacilitationThird-party or vendor payments

                    Whitford's Italian and Turkish subsidiaries kept selling coatings to Iran after the 2012 rule extended Iran sanctions to US-owned foreign entities, and after a non-specialist regulatory manager said indirect sales were fine, the US managing director for Europe devised a plan to sell through third-party distributors with no Iran references. Payments went to and from an Iranian sales agent.

                    “instructing that sales to Iran go indirectly through third-party distributors and documents related to those sales avoid referencing Iran”
                    Mitigating and aggravating factors
                    Mitigating
                    • substantial cooperation including data analysis and tolling, internal investigation without subpoena
                    • no penalty notice or Finding of Violation in prior five years
                    • significant remedial measures
                    Aggravating
                    • reckless given long history of Iran sales and affirmative steps to continue indirectly
                    • US managing director and senior managers had actual knowledge and facilitated
                    • $3.05 million economic benefit to Iran over three years

                    Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                    Jul 16, 2020Settlement$665,112

                    Essentra FZE Company Limited

                    Manufacturing and trade (cigarette filters) · North Korea program · 3 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: yes

                    FacilitationCustomer or counterparty due diligenceThird-party or vendor payments

                    A senior manager at Essentra FZE agreed to sell cigarette filters to North Korea through front companies in China and elsewhere, with contracts naming only third-country parties, and received three payments into accounts at the foreign branch of a US bank. The OFAC amount was satisfied by a larger DOJ penalty.

                    ““[D]on’t mention that customer is in my country… You just mention China or where else.”
                    Mitigating and aggravating factors
                    Mitigating
                    • no penalty notice or Finding of Violation in prior five years
                    • substantial cooperation and ongoing cooperation commitment
                    Aggravating
                    • willful concealment of the DPRK nexus despite company policy
                    • actual knowledge of senior manager and employee
                    • significant harm by causing US persons to benefit the DPRK
                    • part of a sophisticated group

                    Source: OFAC enforcement release (PDF), United Arab Emirates; read Nov. 1, 2026.

                    Jul 8, 2020Settlement$134,523

                    Amazon.com, Inc.

                    Other: e-commerce · Crimea and Iran and Syria and Cuba and North Korea and Sudan and Narcotics and WMD and Transnational Criminal and DRC and Venezuela and Zimbabwe and SDN/counterterrorism programs · violation count not stated · AP or vendor relevant · self-disclosed: yes · egregious: no

                    Screening skipped data fieldsName matching false negativeCustomer or counterparty due diligence

                    Amazon's automated screening did not flag orders whose address fields read 'Yalta, Krimea', orders shipped to Iranian embassies in third countries, or in several hundred cases correctly spelled SDN names and addresses, so it sold low-value goods to SDNs and people in Crimea, Iran and Syria. It also reported 362 Crimea wind-down transactions late, which nullified the general license for them.

                    “Amazon did not properly review or assess addresses, customer names, or common variations of such data as part of its sanctions screening”
                    Mitigating and aggravating factors
                    Mitigating
                    • no penalty notice or Finding of Violation in prior five years
                    • voluntary self-disclosure, data analysis, tolling and internal investigation without subpoena
                    • significant remedial measures and compliance commitments
                    Aggravating
                    • failed to properly review addresses, customer names and common variations
                    • some orders were personal security products for Iranian embassy staff
                    • one of the largest and most sophisticated companies in the world

                    Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                    May 6, 2020Settlement$257,862

                    BIOMIN America, Inc.

                    Manufacturing and trade (animal nutrition) · Cuba program · 44 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

                    FacilitationNo compliance programCustomer or counterparty due diligence

                    BIOMIN America took purchase orders from Alfarma in Cuba, had its foreign affiliates fill them and collected commissions, a structure its managers wrongly believed was lawful. The sales were likely licensable under the agricultural general license but the company had no OFAC program and never sought advice.

                    “BIOMIN America coordinated, and received commissions on, these sales to Alfarma as executed by its foreign affiliates”
                    Mitigating and aggravating factors
                    Mitigating
                    • transactions may have been licensable
                    • no penalty notice or Finding of Violation in prior five years
                    • training with outside counsel and written policies
                    • clear and timely cooperation with tolling
                    Aggravating
                    • reckless in developing and running the structure for years
                    • management aware and involved
                    • divisions of a sophisticated international group

                    Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                    Feb 26, 2020Settlement$7,829,640

                    Société Internationale de Télécommunications Aéronautiques SCRL (SITA)

                    Software (air transport IT and messaging services) · SDN/counterterrorism program · 9,256 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

                    Customer or counterparty due diligenceNo compliance program

                    SITA continued to provide US-hosted messaging, check-in software and lost baggage tracing to member airlines Mahan Air, Syrian Arab Airlines, Caspian Air and others after they were designated as SDGTs, having cut only some services on designation. It described its compliance program as reactive and lacking a comprehensive approach to US sanctions.

                    “SITA described its compliance program up until that point as primarily reactive”
                    Mitigating and aggravating factors
                    Mitigating
                    • no penalty notice or Finding of Violation in prior five years
                    • small percentage of business
                    • extensive remediation including customer and supplier screening and expulsion of the airlines
                    • detailed cooperation and multiple tolling agreements
                    Aggravating
                    • actual knowledge of providing services to SDGTs
                    • benefited airlines sanctioned for supporting terrorism
                    • sophisticated entity operating in virtually every country

                    Source: OFAC enforcement release (PDF), Switzerland; read Nov. 1, 2026.

                    Jan 27, 2020Settlement$1,125,000

                    Eagle Shipping International (USA) LLC

                    Logistics and freight (shipping) · Burma program · 36 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: yes

                    Third-party or vendor paymentsCustomer or counterparty due diligenceFacilitation

                    Eagle carried sea sand from Burma to Singapore for a charterer whose shipper was Myawaddy Trading, an SDN, accepting revised bills of lading that swapped in another shipper's name over the captain's objections. It then kept carrying Myawaddy sand after OFAC denied its license application, which the former president did not pass on.

                    “Eagle resumed shipping sand procured from Myawaddy”
                    Mitigating and aggravating factors
                    Mitigating
                    • no penalty notice or Finding of Violation in prior five years
                    • substantial cooperation under new management including internal investigation and tolling
                    • significant remediation including a compliance officer and formal program
                    Aggravating
                    • reckless disregard of OFAC's license denial and warning signs
                    • former President involved and approved
                    • significant economic benefit to Burma's military regime
                    • sophisticated global shipping company

                    Source: OFAC enforcement release (PDF), United States (Marshall Islands company); read Nov. 1, 2026.

                    Jan 21, 2020Settlement$12,150

                    Park Strategies, LLC

                    Other: lobbying and consulting · SDN/counterterrorism program · 2 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

                    Customer or counterparty due diligenceNo screening performed

                    A New York lobbying firm signed a $30,000 contract with Al-Barakaat Group of Companies Somalia, an SDGT, and accepted the first $10,000 payment, with executives aware of the designation. Lobbying is not covered by the general license for legal services; the firm later blocked the funds and self-disclosed.

                    “adopting new OFAC screening procedures prior to entering into contracts with potential clients”
                    Mitigating and aggravating factors
                    Mitigating
                    • no penalty notice or Finding of Violation in prior five years
                    • suspended performance, blocked the funds, adopted OFAC screening before contracts
                    Aggravating
                    • executives had actual knowledge and participated
                    • harm by dealing with an SDGT designated for terrorist financing

                    Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                    Dec 9, 2019Settlement$170,535

                    Allianz Global Risks US Insurance Company

                    Insurance · Cuba program · 6,474 apparent violations · not an AP or vendor case · self-disclosed: yes · egregious: no

                    Screening skipped data fieldsNo compliance program

                    AGR's Canadian branch fronted travel insurance policies that covered Canadians' trips to Cuba, paying 864 Cuba-related claims. Neither the branch nor its underwriting manager collected travel destinations at issuance, and the practice continued for years after notices in 2010.

                    “Neither the underwriting manager nor AGR Canada collected information regarding the travel destination upon policy issuance”
                    Mitigating and aggravating factors
                    Mitigating
                    • no supervisory or managerial awareness
                    • no Finding of Violation or penalty notice in prior five years
                    • enhanced OFAC program and hired a compliance officer for Canada
                    • voluntary self-disclosure, tolling and organized productions
                    Aggravating
                    • failed minimal caution for almost five years
                    • did not investigate 2010 notifications
                    • ignored warning signs
                    • actual knowledge from 2010
                    • economic benefit to Cuba
                    • no OFAC procedures for fronting

                    Source: OFAC enforcement release (PDF), United States (Canadian branch); read Nov. 1, 2026.

                    Dec 9, 2019Settlement$66,212

                    ACE Limited (Chubb Limited as successor), for ACE Europe

                    Insurance · Cuba program · 20,291 apparent violations · not an AP or vendor case · self-disclosed: yes · egregious: no

                    Screening skipped data fieldsCustomer or counterparty due diligence

                    ACE Europe, a UK subsidiary of a US holding company, received 20,218 premiums and paid 73 claims on travel insurance covering trips to Cuba, mostly through a European online travel agency. Its regional compliance team had concluded the EU blocking regulation governed and so omitted sanctions exclusion clauses from global policies.

                    “these policies did not contain a sanctions exclusionary clause”
                    Mitigating and aggravating factors
                    Mitigating
                    • many transactions would be licensed after the January 2015 CACR amendments
                    • no penalty notice or Finding of Violation in prior five years
                    • voluntary self-disclosure and cooperation
                    • remedial action
                    Aggravating
                    • inadequate controls including no sanctions exclusionary clauses
                    • business leaders and compliance knew of Cuba coverage but relied on an erroneous legal conclusion
                    • multi-year pattern
                    • economic benefit to Cuba
                    • large sophisticated financial institution

                    Source: OFAC enforcement release (PDF), Switzerland (UK subsidiary of US holding company); read Nov. 1, 2026.

                    Nov 25, 2019Settlement$466,912

                    Apple, Inc.

                    Software (technology and app store) · Narcotics program · 47 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

                    Name matching false negativeScreening skipped data fieldsThird-party or vendor paymentsCustomer or counterparty due diligence

                    Apple's screening tool did not match the upper case 'SIS DOO' in its developer records with 'SIS d.o.o.' on the SDN List, and it screened only users tagged as developers, so it missed the designated owner listed as account administrator. For over two years Apple hosted and sold the blocked apps, let SIS transfer them to two new companies and remitted 47 payments, continuing some payments even after it finally identified SIS.

                    “failure to match the upper case name “SIS DOO” in Apple’s system with the lower case name “SIS d.o.o.””
                    Mitigating and aggravating factors
                    Mitigating
                    • payments not significant relative to Apple's volume
                    • no penalty notice or Finding of Violation in prior five years
                    • responded to numerous information requests and tolled the statute
                    Aggravating
                    • reckless disregard shown by multiple points of failure over a long period
                    • significant economic benefit to SIS and its owner
                    • large sophisticated global organization
                    • failed to act promptly after identifying SIS in February 2017

                    Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                    Nov 7, 2019Settlement$210,600

                    Apollo Aviation Group, LLC (now Carlyle Aviation Partners)

                    Other: aircraft leasing · Sudan program · 12 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

                    Customer or counterparty due diligenceThird-party or vendor payments

                    Apollo leased three aircraft engines to a UAE company that subleased them to a Ukrainian airline, which installed them on aircraft wet leased to Sudan Airways, an SDN. The leases barred use in sanctioned countries but Apollo did not obtain compliance certificates or monitor where the engines flew until records came back at lease end.

                    “Apollo did not obtain U.S. law export compliance certificates from lessees and sublessees”
                    Mitigating and aggravating factors
                    Mitigating
                    • no personnel had actual knowledge
                    • no penalty notice or Finding of Violation in prior five years
                    • remedial measures including compliance staff and systems
                    • clear and organized information
                    Aggravating
                    • harm from use of engines in Sudan by an SDN
                    • large sophisticated entity
                    • failed to monitor or verify engine whereabouts during the leases

                    Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                    Oct 1, 2019Settlement$2,718,581

                    The General Electric Company (Getsco Technical Services, Bentley Nevada, GE Betz)

                    Manufacturing and trade (industrial conglomerate) · Cuba program · 289 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

                    Third-party or vendor paymentsName matching false negativeScreening skipped data fieldsCustomer or counterparty due diligence

                    Three GE units accepted 289 checks totaling about $8 million from The Cobalt Refinery Company, a Cuban SDN since 1995, as third-party payer for invoices issued to a Canadian mining customer that was in a joint venture with the Cuban government. The checks carried Cobalt's full SDN name, but GE's screening software screened only the acronym Corefco and never alerted.

                    “the GE Companies’ sanctions screening software, which screened only the abbreviation of the SDN’s name, never alerted on Cobalt’s name”
                    Mitigating and aggravating factors
                    Mitigating
                    • no penalty notice or Finding of Violation in prior five years
                    • found through testing and auditing, remediation and training video case study
                    • multiple tolling agreements
                    Aggravating
                    • failed to take reasonable care given sophistication, receiving payments on their face from an SDN for four years
                    • substantial harm from high-value transactions with a Cuban SDN
                    • disclosures left uncertainty and were disorganized with inaccuracies

                    Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                    Sep 17, 2019Settlement$4,000,000

                    British Arab Commercial Bank plc

                    Banking · Sudan program · 72 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: yes

                    Facilitation

                    BACB ran USD accounts for seven Sudanese banks and funded a nostro account at a foreign bank with 72 bulk USD wires that passed through US banks, then paid Sudanese parties from that account outside the US. Managers and a compliance team member knew of the structure and how it was meant to avoid US sanctions.

                    “the risks surrounding, the use of complex payment structures, including bulk funding arrangements”
                    Mitigating and aggravating factors
                    Mitigating
                    • no penalty notice or Finding of Violation in prior five years
                    • significant investigative leads and full cooperation with tolling
                    • weak financial position, penalty reduced in consultation with the UK PRA
                    • exited Sudan market, new senior management, centralized compliance
                    Aggravating
                    • reckless years-long practice that obscured purpose from US banks
                    • ignored warning signs including enforcement against other European banks
                    • senior management aware and involved
                    • substantial economic benefit to Sudan
                    • sophisticated financial institution

                    Note: proposed penalty of $228,840,000 reduced to $4,000,000 with the remainder suspended because of the bank's operating capacity.

                    Source: OFAC enforcement release (PDF), United Kingdom; read Nov. 1, 2026.

                    Aug 16, 2019Settlement$345,315

                    Atradius Trade Credit Insurance, Inc.

                    Insurance (trade credit insurance) · Narcotics program · 2 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

                    Third-party or vendor paymentsNo screening performed

                    Five months after Grupo Wisa was designated under the Kingpin Act, a US cosmetics company assigned Atradius its $5.7 million receivable from Grupo Wisa, and Atradius filed in the Panamanian liquidation and collected $4 million. OFAC said it never analyzed or asked whether taking the SDN's debt and payment was permitted.

                    “ATCI did not undertake any meaningful analysis or otherwise seek confirmation from OFAC”
                    Mitigating and aggravating factors
                    Mitigating
                    • no penalty notice or Finding of Violation in prior five years
                    • voluntary full internal review and remedial action
                    • compliance commitments
                    Aggravating
                    • no meaningful analysis or confirmation from OFAC
                    • subsidiary of a sophisticated global trade credit conglomerate

                    Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                    Aug 6, 2019Settlement$1,709,325

                    PACCAR Inc (for DAF Trucks N.V.)

                    Manufacturing and trade (trucks) · Iran program · 63 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

                    Third-party or vendor paymentsCustomer or counterparty due diligence

                    DAF, PACCAR's Dutch subsidiary, sold 63 trucks through German and Bulgarian dealers and a Dutch trader that resold them to buyers in Iran. In one case a dealer re-submitted an order DAF had refused as Iran-bound the same day with identical specifications labeled for Russia, and DAF processed it without inquiry.

                    “submitted a pricing request for a new order of trucks purportedly destined for a customer or end-user in Russia with virtually identical specifications”
                    Mitigating and aggravating factors
                    Mitigating
                    • no penalty notice or Finding of Violation in prior five years
                    • had a trade sanctions program with dealer contract prohibitions
                    • internal investigation, terminated employees, cancelled 20 trucks, annual training, policy limiting direct sales
                    • detailed voluntary self-disclosure and tolling
                    Aggravating
                    • employees ignored warning signs and sold to customers known to resell to Iran
                    • each case involved an employee with knowledge or reason to know
                    • millions of dollars of economic benefit to Iran
                    • large sophisticated international parent

                    Source: OFAC enforcement release (PDF), United States (Netherlands subsidiary); read Nov. 1, 2026.

                    Jun 13, 2019Settlement$222,705

                    Hotelbeds USA, Inc.

                    Travel · Cuba program · 703 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: not stated

                    FacilitationNo compliance program

                    Hotelbeds USA sold Cuba hotel stays to 703 non-US travelers and told clients to pay a Spanish account that then reimbursed the US company, believing non-US clients and non-US bank accounts put it outside the rules. Staff knew a US bank had blocked a related payment and that OFAC had denied a license request.

                    “gave its clients specific instructions to direct their payments for the Cuba-related transactions to an account in Spain”
                    Mitigating and aggravating factors
                    Mitigating
                    • under one percent of business
                    • no penalty notice or Finding of Violation in prior five years
                    • enhanced screening tool, more resources, more compliance staff
                    • extensive internal investigation and 1,043 days of tolling
                    Aggravating
                    • supervisors aware or participating
                    • harm to Cuba program objectives
                    • large sophisticated company
                    • only an informal compliance program

                    Note: Cuba Penalty Schedule case, prior to agency notice.

                    Source: OFAC enforcement release (PDF), United States (Spanish parent); read Nov. 1, 2026.

                    Jun 13, 2019Settlement$325,406

                    Expedia Group, Inc.

                    Travel · Cuba program · 2,221 apparent violations · not an AP or vendor case · self-disclosed: yes · egregious: not stated

                    Geolocation or IP data ignoredCustomer or counterparty due diligenceNo compliance program

                    Expedia's foreign subsidiaries booked Cuba travel for 2,221 people because of gaps in technical controls and because staff did not understand US sanctions applied. One acquired subsidiary was not told it was subject to US law until 15 months after acquisition.

                    “Expedia failed to inform the subsidiary until approximately 15 months after Expedia acquired the subsidiary that it was subject to U.S. jurisdiction”
                    Mitigating and aggravating factors
                    Mitigating
                    • no penalty notice or Finding of Violation in prior five years
                    • significant corporate-wide remedial measures
                    • cooperation including data analytics and tolling
                    Aggravating
                    • failed minimal caution, pattern across entities and years
                    • harm to Cuba program objectives
                    • sophisticated international travel provider

                    Note: Cuba Penalty Schedule case, prior to agency notice.

                    Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                    Jun 13, 2019Settlement$40,320

                    An Individual and Cubasphere Inc.

                    Travel · Cuba program · violation count not stated · not an AP or vendor case · self-disclosed: no · egregious: not stated

                    No compliance program

                    A tour operator and its president ran four Cuba trips for 104 people under religious general license cover letters while the real itineraries were tourism, after OFAC had told them the conduct was likely prohibited. They also urged clients to carry no receipts and give false statements if questioned.

                    “the itineraries from the U.S. religious organizations did not match the itineraries that the Individual and Cubasphere offered”
                    Mitigating and aggravating factors
                    Mitigating
                    • no prior sanctions history
                    • natural person and small company
                    • cooperation including tolling in post-investigation proceedings
                    Aggravating
                    • willful conduct with knowledge
                    • knowingly facilitated others' unauthorized travel
                    • significant harm given publicity and unlicensable conduct
                    • no adequate compliance procedures
                    • no remedial action

                    Note: Cuba Penalty Schedule case, subsequent to agency notice.

                    Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                    Jun 7, 2019Settlement$401,697

                    Western Union Financial Services, Inc.

                    Payments (money services business) · SDN/counterterrorism program · 4,977 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

                    Screening skipped data fieldsThird-party or vendor paymentsCustomer or counterparty due diligence

                    A Gambian bank acting as Western Union master agent used Kairaba Shopping Center, designated an SDGT in 2010, as a sub-agent payout location for over four years. Western Union stored KSC as a location of the bank rather than a legal entity and did not screen location data, so 4,977 remittances were paid out there.

                    “Western Union did not screen location data for sanctions-related issues as part of its review process”
                    Mitigating and aggravating factors
                    Mitigating
                    • no penalty notice or Finding of Violation in prior five years
                    • global sanctions policy requiring master agents to vet sub-agents
                    • corrective plan for sub-agent due diligence already underway
                    • one-time screening of all sub-agent and location data
                    • voluntary self-disclosure and tolling
                    Aggravating
                    • reckless disregard in failing to identify both KSC locations after discovery
                    • processed SDN transactions for over four years
                    • had reason to know with reasonable diligence
                    • substantial harm including benefit to an SDN
                    • large sophisticated institution

                    Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                    May 2, 2019Settlement$871,837

                    MID-SHIP Group LLC

                    Logistics and freight (ship brokerage) · WMD program · 5 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: yes

                    No screening performedThird-party or vendor paymentsAlerts cleared wrongly

                    MID-SHIP's Chinese and Turkish subsidiaries brokered charters performed by two blocked IRISL vessels and the company processed five funds transfers totaling $472,861 tied to them, while holding documents with the vessels' IMO numbers. Managers knew banks had held or rejected payments for compliance reasons and discussed receiving one in a non-USD currency instead.

                    “MID-SHIP was in possession of multiple documents identifying the vessels by their respective IMO numbers”
                    Mitigating and aggravating factors
                    Mitigating
                    • no penalty notice or Finding of Violation in prior five years and transactions were 0.05 percent of volume
                    • OFAC compliance officer, training, vessel ownership checks, charter party clauses, screening every vessel and party to a wire
                    • multiple tolling agreements, 1,231 days
                    Aggravating
                    • reckless disregard
                    • managers knew of and participated
                    • economic benefit to and dealing in services of IRISL
                    • sophisticated global shipping company in a high-risk industry

                    Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                    Apr 25, 2019Settlement$75,375

                    Haverly Systems, Inc.

                    Software · Ukraine/Russia program · 2 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

                    No compliance programAlerts cleared wronglyCustomer or counterparty due diligence

                    Haverly collected two software invoices from Rosneft, an SSI List entity, more than 90 days after issuance, which made the receivable prohibited new debt under Directive 2. After banks rejected four payment attempts with SWIFT messages citing sectoral sanctions, Haverly re-dated the invoice at Rosneft's suggestion and got paid.

                    “At the suggestion of Rosneft, Haverly re-issued and re-dated the second invoice”
                    Mitigating and aggravating factors
                    Mitigating
                    • minimal harm and likely licensable
                    • no penalty notice or Finding of Violation in prior five years
                    • small company
                    • created a Sanctions Compliance Officer and client screening program
                    Aggravating
                    • reckless disregard of repeated warning signs on the second invoice
                    • management had actual knowledge
                    • no formal OFAC compliance program

                    Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                    Apr 15, 2019Settlement$37,316,322

                    UniCredit S.p.A.

                    Banking · Cuba and Iran and Burma and Sudan and Syria programs · 612 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: not stated

                    FacilitationScreening skipped data fields

                    The UniCredit Group parent processed 612 payments involving Cuba, Iran, Burma, Sudan and Syria through US banks in a non-transparent manner. Part of the UniCredit Group global settlement.

                    “has agreed to a settlement amount of $37,316,322 to settle its potential civil liability for 612 apparent violations”
                    Mitigating and aggravating factors
                    Mitigating
                    • no penalty notice or Finding of Violation in prior five years
                    • internal investigation, timely responses and tolling
                    • remedial action
                    Aggravating

                      The release lists further factors; see the source.

                      Note: see source for egregiousness split.

                      Source: OFAC enforcement release (PDF), Italy; read Nov. 1, 2026.

                      Apr 15, 2019Settlement$20,326,340

                      UniCredit Bank Austria AG

                      Banking · Iran and Sudan and Burma and Syria and Cuba programs · 127 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: mixed

                      FacilitationScreening skipped data fields

                      Bank Austria processed 127 payments through US banks using non-transparent practices that concealed sanctioned parties and countries from US intermediaries. Part of the UniCredit Group global settlement.

                      “utilized nontransparent payment practices to process transactions to or through the United States”
                      Mitigating and aggravating factors
                      Mitigating
                      • no penalty notice or Finding of Violation in prior five years
                      • internal investigation, timely responses and tolling
                      • remedial action
                      Aggravating

                        The release lists further factors; see the source.

                        Note: 60 non-egregious, 67 egregious.

                        Source: OFAC enforcement release (PDF), Austria; read Nov. 1, 2026.

                        Apr 15, 2019Settlement$553,380,759

                        UniCredit Bank AG

                        Banking · WMD and Cuba and Burma and Sudan and Syria and Iran and Libya and SDN/counterterrorism programs · 2,158 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: yes

                        Facilitation50 Percent Rule missedScreening skipped data fields

                        UniCredit Bank AG ran USD accounts for IRISL and its affiliates and used auto-transfer arrangements that hid IRISL's interest from US intermediaries for almost two years after designation, and followed a written guide for processing payments in an 'OFAC neutral manner'. Part of a global settlement with DOJ, the Manhattan DA, the Federal Reserve and NYDFS.

                        “step-by-step instructions for handling transactions in an “OFAC neutral manner””
                        Mitigating and aggravating factors
                        Mitigating
                        • no penalty notice or Finding of Violation in prior five years
                        • extensive internal investigation and tolling
                        • remedial action
                        • some IRISL violations occurred shortly after designation
                        Aggravating
                        • reckless failure to control IRISL-related payments after designation and an internal directive
                        • removed Fairway from the IRISL customer group without confirming IRISL had no interest
                        • willful circumvention through a formal procedures guide for five years
                        • reason to know oil cargoes went to Iran from documents examined

                        Source: OFAC enforcement release (PDF), Germany; read Nov. 1, 2026.

                        Apr 11, 2019Settlement$213,866

                        Acteon Group Ltd. (Seatronics) and KKR & Co. Inc.

                        Other: marine equipment rental · Cuba and Iran programs · 16 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

                        Customer or counterparty due diligenceThird-party or vendor payments

                        Seatronics units rented or sold equipment and sent engineers to vessels working in Cuban waters on 13 occasions, and the Abu Dhabi branch rented or sold equipment to UAE customers that deployed it on vessels in Iranian waters, despite group guidance prohibiting both. The US parent KKR's potential liability for the Iran counts was settled in the same agreement.

                        “rented or sold marine equipment to two UAE companies that appear to have embarked the equipment onboard vessels that operated in Iranian territorial waters”
                        Mitigating and aggravating factors
                        Mitigating

                          The release lists further factors; see the source.

                          Aggravating
                          • reckless disregard in supplying goods and services to vessels in Cuban and Iranian waters
                          • multi-year pattern
                          • senior management knew of Cuba work and should have known of Iran risk

                          Source: OFAC enforcement release (PDF), United Kingdom (US-owned); read Nov. 1, 2026.

                          Apr 11, 2019Settlement$227,500

                          Acteon Group Ltd. and 2H Offshore Engineering Ltd.

                          Other: offshore engineering · Cuba program · 7 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: yes

                          FacilitationCustomer or counterparty due diligence

                          2H Offshore's Malaysian affiliates produced engineering reports and sent engineers to Cuba for oil projects run by Petronas, Repsol, PdVSA Cuba and Zarubezhneft, with directors renaming projects and expense entries to hide the word Cuba. Acteon's own 2007 guidance barred Cuba work even through third countries.

                          “replace the words “Cuba” or “Cuban” with “Central America” or “Central American” in the Technical Director’s post-trip expense report”
                          Mitigating and aggravating factors
                          Mitigating
                          • voluntary submissions, responsiveness and three tolling agreements

                          The release lists further factors; see the source.

                          Aggravating
                          • willful conduct despite prior notice, in one case approved by Acteon
                          • reckless disregard
                          • deliberate concealment by senior managers
                          • multi-year pattern
                          • actual knowledge
                          • ineffective compliance program
                          • economic benefit to the Cuban government
                          • sophisticated businesses aware of the law

                          Source: OFAC enforcement release (PDF), United Kingdom (US-owned); read Nov. 1, 2026.

                          Apr 9, 2019Settlement$18,016,283

                          Standard Chartered Bank (Zimbabwe-related conduct)

                          Banking · Zimbabwe program · 1,795 apparent violations · not an AP or vendor case · self-disclosed: yes · egregious: no

                          50 Percent Rule missedScreening skipped data fieldsCustomer or counterparty due diligence

                          SCB's Zimbabwe affiliate kept accounts for SDNs and entities owned 50 percent or more by SDNs, whose funds transfers and card transactions were net settled through SCB New York in 1,795 transactions worth $76.8 million. Staff did not realize the SDN customers' Zimbabwe-issued cards could be used outside Zimbabwe, including in the US.

                          “parties that were owned 50 percent or more, directly or indirectly, by persons on the SDN List”
                          Mitigating and aggravating factors
                          Mitigating
                          • cooperation including tolling agreement
                          Aggravating
                          • actual knowledge of SDN customer relationships for years
                          • compliance supervisors knew of exposure
                          • significant harm to ZSR objectives
                          • inadequate compliance program
                          • large sophisticated institution
                          • ring-fencing of SDN customers insufficient
                          • staff unaware cards could be used abroad

                          Source: OFAC enforcement release (PDF), United Kingdom; read Nov. 1, 2026.

                          Apr 9, 2019Settlement$639,023,750

                          Standard Chartered Bank (global settlement conduct)

                          Banking · Burma and Cuba and Iran and Sudan and Syria programs · 9,335 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: yes

                          Customer or counterparty due diligenceGeolocation or IP data ignoredFacilitation

                          SCB's Dubai branches held accounts for Iranian general trading and petrochemical companies and processed 9,335 USD transactions through New York for customers who sent instructions while located or resident in Iran. Part of a global settlement with the Federal Reserve, DOJ, the Manhattan DA, NYDFS and the UK FCA.

                          “customers that sent payment instructions to SCB Dubai while physically located and/or ordinarily resident in Iran”
                          Mitigating and aggravating factors
                          Mitigating
                          • substantial cooperation including tolling and voluminous organized productions
                          • remedial efforts
                          • some Syria transactions shortly after E.O. 13582
                          • no penalty notice or Finding of Violation in prior five years
                          Aggravating
                          • reckless disregard
                          • supervisory and compliance personnel involved in discussions of risky customers
                          • significant harm giving dozens of sanctioned companies access to the US financial system
                          • inadequate compliance program with systemic deficiencies
                          • large sophisticated institution

                          Source: OFAC enforcement release (PDF), United Kingdom; read Nov. 1, 2026.

                          Mar 27, 2019Settlement$1,869,144

                          Stanley Black & Decker, Inc. (for Jiangsu Guoqiang Tools Co. Ltd.)

                          Manufacturing and trade (power tools) · Iran program · 23 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: yes

                          Third-party or vendor paymentsFacilitation

                          After acquiring 60 percent of GQ in China, having made ending Iran sales a closing condition, Stanley Black & Decker gave one training and did not audit, and GQ's board members and export manager kept shipping power tools to Iran through six trading companies with fake bills of lading. OFAC stressed post-acquisition monitoring of subsidiaries.

                          “Stanley Black & Decker did not implement procedures to monitor or audit GQ’s operations to ensure that its Iran-related sales did not recur”
                          Mitigating and aggravating factors
                          Mitigating
                          • no penalty notice or Finding of Violation in prior five years
                          • immediate remediation including halting exports and an independent investigator
                          • extensive investigation, detailed responses and multiple tolling agreements
                          Aggravating
                          • willful violations by GQ senior management
                          • economic benefit to Iran over 18 months in a systematic scheme
                          • sophisticated exporter with leadership aware of sanctions

                          Source: OFAC enforcement release (PDF), United States (China subsidiary); read Nov. 1, 2026.

                          Feb 21, 2019Settlement$506,250

                          ZAG IP, LLC

                          Other: commodity trading, cement materials · Iran program · 5 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

                          Third-party or vendor paymentsNo compliance program

                          When its Indian supplier could not deliver, ZAG bought 263,563 tons of Iranian-origin cement clinker from a UAE trading company and resold it to a Tanzanian buyer, relying on the seller's claim that the goods were not subject to sanctions. Senior management knew the clinker was made in Iran and shipped from an Iranian port.

                          “Relying on the Alternative Supplier’s misrepresentation that the cement clinker was not subject to U.S. economic sanctions on Iran”
                          Mitigating and aggravating factors
                          Mitigating
                          • no penalty notice or Finding of Violation in prior five years
                          • small business
                          • thorough internal investigation, compliance manual and sanctions compliance officer
                          • organized and timely cooperation
                          Aggravating
                          • reckless disregard despite risk indicators, only limited due diligence
                          • senior management aware of Iranian origin
                          • significant economic benefit to Iran
                          • sophisticated global trader
                          • no effective OFAC compliance program

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Feb 14, 2019Penalty notice$5,512,564

                          AppliChem GmbH (subsidiary of Illinois Tool Works)

                          Manufacturing and trade (chemical reagents) · Cuba program · 304 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: yes

                          FacilitationThird-party or vendor paymentsCustomer or counterparty due diligence

                          After ITW acquired AppliChem and ordered an end to Cuba sales, the former owners built 'Caribbean Procedures' that used the code word Caribbean, outsourced shipping paperwork to a logistics company and a hazmat consultant so no document mentioned Cuba, and sold to Cuba on 304 invoices through a Berlin intermediary. OFAC assessed a penalty despite ITW's self-disclosure.

                          “Cuba was referred to by the code word “Caribbean””
                          Mitigating and aggravating factors
                          Mitigating
                          • ITW's thorough voluntary self-disclosure, prompt responses, internal investigation and tolling
                          Aggravating
                          • willful conduct by management
                          • written procedures to run a pattern of violations
                          • $3.4 million in sales over five years, significant harm to the Cuba embargo
                          • size and sophistication, subsidiary of ITW

                          Source: OFAC enforcement release (PDF), Germany (US-owned); read Nov. 1, 2026.

                          Feb 7, 2019Settlement$13,381

                          Kollmorgen Corporation (for Elsim Elektroteknik, Turkey)

                          Manufacturing and trade (motion control and automation) · Iran program · 6 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

                          FacilitationCustomer or counterparty due diligence

                          Despite extensive pre- and post-acquisition controls by Kollmorgen, including customer database reviews, blocked customers and quarterly certifications, Elsim's managers sent employees to service machines in Iran, logged the trips as vacation, falsely certified compliance and later deleted Iran references. The small penalty reflected Kollmorgen's efforts; OFAC separately designated the responsible Elsim manager.

                          “Elsim management regularly and fraudulently certified to Kollmorgen that no Elsim products or services were being sent to Iran”
                          Mitigating and aggravating factors
                          Mitigating
                          • no penalty notice or Finding of Violation in prior five years
                          • effective and extensive internal investigation and comprehensive self-disclosure
                          • extensive preventative and remedial conduct
                          Aggravating
                          • Elsim willfully provided goods and services to Iran
                          • management directed employee travel to Iran
                          • management concealed violations by deleting and falsifying records
                          • economic benefit to Iran

                          Source: OFAC enforcement release (PDF), United States (Turkish affiliate); read Nov. 1, 2026.

                          Jan 31, 2019Settlement$996,080

                          e.l.f. Cosmetics, Inc.

                          Other: cosmetics importer · North Korea program · 156 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

                          Third-party or vendor paymentsNo compliance program

                          ELF imported 156 shipments of false eyelash kits worth $4.4 million from two Chinese suppliers, about 80 percent of which contained materials sourced from North Korea. Its supplier audits looked only at quality, not sanctions or country of origin.

                          “supply chain audits that verify the country of origin of goods and services used in ELF’s products”
                          Mitigating and aggravating factors
                          Mitigating
                          • no actual knowledge
                          • no penalty notice or Finding of Violation in prior five years
                          • not a significant part of business
                          • immediate disclosure, tolling and complete responses
                          Aggravating
                          • US-origin funds may have reached the North Korean government
                          • large sophisticated company with substantial international trade
                          • compliance program non-existent or inadequate with insufficient supply chain due diligence

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Dec 20, 2018Settlement$7,772,102

                          Zoltek Companies, Inc.

                          Manufacturing and trade (carbon fiber) · Belarus program · 26 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: mixed

                          Third-party or vendor payments50 Percent Rule missedNo screening performedFacilitation

                          US executives of Zoltek approved 26 purchases of acrylonitrile by its Hungarian subsidiary from Naftan, a Belarusian SDN, over nearly four years, including after a subsidiary employee flagged the designation and after third parties confirmed the trading partner Polymir was a Naftan subsidiary. More than $18 million went to the Belarusian government entity.

                          “screen its vendors, and their parent and subsidiary companies, against government restricted lists on a daily basis”
                          Mitigating and aggravating factors
                          Mitigating
                          • no penalty notice or Finding of Violation in prior five years
                          • voluntary self-disclosure, detailed information and 643 days of tolling
                          • terminated conduct, expanded compliance role, daily vendor and parent-subsidiary screening, training academy
                          Aggravating
                          • reckless disregard and no OFAC checks in risk mitigation
                          • senior executives aware and participating
                          • significant harm, over $18 million to a Belarusian government entity
                          • large entities with significant international trade
                          • executives discussed the sanctions issue but kept approving transactions

                          Note: pre-February 2015 purchases non-egregious; later purchases egregious.

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Dec 12, 2018Settlement$2,774,972

                          Yantai Jereh Oilfield Services Group Co., Ltd.

                          Manufacturing and trade (oilfield equipment) · Iran program · 11 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: yes

                          Third-party or vendor paymentsFacilitationNo compliance program

                          Two Jereh sales managers used a Chinese trading company and a UAE distributor as intermediaries to sell products containing US-origin goods to Iranian end users, and the intermediary contracts omitted the company's own anti-re-export clause. Nine of 11 shipments happened after BIS began asking questions, and the conduct stopped only when BIS listed the company.

                          “compliance controls were largely non-existent and, when in place, were ineffective and easily circumvented”
                          Mitigating and aggravating factors
                          Mitigating
                          • no prior sanctions history
                          • cooperation including disclosing other possible violations
                          • 298-day tolling
                          • remedial steps including terminating responsible employees and external compliance review
                          Aggravating
                          • willful conduct with systematic obfuscation continuing during a US investigation
                          • management-level knowledge
                          • intermediaries established to conceal transactions
                          • falsified export filings and false statements
                          • multi-year pattern worth over $500,000 to Iran
                          • sophisticated international corporation

                          Source: OFAC enforcement release (PDF), China; read Nov. 1, 2026.

                          Nov 27, 2018Settlement$87,507

                          Cobham Holdings, Inc. (for former subsidiary Aeroflex/Metelics, Inc.)

                          Manufacturing and trade (electronic components) · Ukraine/Russia program · 3 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

                          50 Percent Rule missedName matching false negativeThird-party or vendor paymentsCustomer or counterparty due diligence

                          Metelics shipped switches and limiters through Canadian and Russian distributors to Almaz Antey Telecommunications, which was 51 percent owned by SDN JSC Almaz-Antey and therefore blocked. Its third-party screening tool used all-word matching even in fuzzy mode, so searching 'Almaz Antey Telecom' did not match the SDN entry 'Almaz Antey' and the compliance director approved the shipments.

                          “the software failed to match “Almaz Antey” when Cobham searched for “Almaz Antey Telecom.””
                          Mitigating and aggravating factors
                          Mitigating
                          • no penalty notice or Finding of Violation in prior five years
                          • detailed disclosure and cooperation
                          • remedial measures
                          • primary transaction straddled changes in the URSR
                          Aggravating
                          • failed to recognize warning signs when exporting to a near-namesake of a blocked person
                          • Director of Global Trade Compliance approved the transactions
                          • economic benefit to a blocked person tied to Russia's defense industry
                          • large sophisticated entities in a sensitive industry
                          • prior apparent violations and an ITAR consent agreement

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Nov 19, 2018Settlement$53,966,916

                          Société Générale S.A.

                          Banking · Cuba and Iran and Sudan programs · 1,077 apparent violations · not an AP or vendor case · self-disclosed: yes · egregious: yes

                          FacilitationScreening skipped data fields

                          Société Générale processed 1,077 transactions involving Cuba, Iran and Sudan through US banks after removing or omitting references to sanctioned parties in payment instructions, continuing practices from earlier stripping instructions. The settlement was part of a global resolution with the Federal Reserve, DOJ, the Manhattan DA and NYDFS.

                          “removed, omitted, obscured, or otherwise failed to include references to OFAC-sanctioned parties”
                          Mitigating and aggravating factors
                          Mitigating
                          • no penalty notice or Finding of Violation in prior five years
                          • cooperation including internal investigation and tolling
                          • remedial action including centralized sanctions compliance function and more staff
                          Aggravating
                          • indications and employee awareness that conduct violated US law
                          • reckless disregard across multiple units
                          • ignored warning signs including US bank rejections and OFAC enforcement actions
                          • numerous employees and managers had actual knowledge
                          • significant economic benefit to sanctioned persons
                          • large sophisticated institution

                          Source: OFAC enforcement release (PDF), France; read Nov. 1, 2026.

                          Oct 5, 2018Finding of violationno penalty

                          JPMorgan Chase & Co.

                          Banking · Narcotics and Syria programs · 85 apparent violations · not an AP or vendor case · self-disclosed: yes · egregious: not stated

                          Name matching false negativeLegacy or unintegrated systemCustomer or counterparty due diligence

                          A vendor-supplied screening system used from about 2007 to 2013 could not match customer names containing hyphens, initials or extra middle or last names, so JPMorgan kept eight accounts and processed 85 transactions for six SDN customers whose names, addresses and birth dates closely matched the list. The bank knew of the weakness from 2010 but took over three years to fully fix it without compensating controls.

                          “failed to identify customer names with hyphens, initials, or additional middle or last names as potential matches”
                          Mitigating and aggravating factors
                          Mitigating
                          • no personnel had actual knowledge
                          • no similar penalty notice or Finding of Violation in prior five years
                          • cooperation including initial disclosure and tolling
                          Aggravating
                          • 85 transactions and eight accounts for SDN customers
                          • two-year pattern from the same screening issue
                          • over three years to fix a known vendor system deficiency
                          • no adequate compensating controls
                          • large sophisticated institution

                          Note: Finding of Violation, no monetary penalty; JPMC provided the initial disclosure.

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Oct 5, 2018Settlement$5,263,171

                          JPMorgan Chase Bank, N.A.

                          Banking · Cuba and Iran and WMD programs · 87 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

                          No screening performedThird-party or vendor paymentsAlerts cleared wrongly

                          As clearing bank for an airline industry net settlement mechanism, JPMorgan processed 87 net payments over four years whose participants included eight airlines that were SDNs, blocked or in sanctioned countries. It had the member lists needed to screen but did not, and missed red flag notices from its client on at least three occasions.

                          “failed to screen participating member entities of the non-U.S. person entity”
                          Mitigating and aggravating factors
                          Mitigating
                          • no managers or supervisors aware
                          • harm much smaller than transaction value because of netting
                          • cooperation including retroactive tolling
                          • screened all participants from February 2012, more compliance staff, new screening software, training
                          Aggravating
                          • reckless disregard in failing to screen members despite having the information
                          • pattern of missed red flags including two express client notifications in 2011
                          • staff had actual knowledge of members in each transaction
                          • economic benefit to several sanctioned entities
                          • large sophisticated institution

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Sep 13, 2018Settlement$1,500,000

                          Epsilon Electronics, Inc.

                          Manufacturing and trade (car audio electronics) · Iran program · 39 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: not stated

                          Third-party or vendor paymentsNo compliance programCustomer or counterparty due diligence

                          Epsilon issued 39 invoices to Asra International, a Dubai distributor it knew or should have known sent most of its products to Iran. After OFAC's 2014 penalty notice was litigated to the D.C. Circuit and remanded, the parties settled for $1.5 million.

                          “a company that Epsilon knew or had reason to know that distributed most, if not all, of its products to Iran”
                          Mitigating and aggravating factors
                          Mitigating
                          • no penalty notice or Finding of Violation in prior five years
                          • small business
                          • some cooperation including one-year tolling
                          • post-litigation remediation including terminating the distributor and a compliance program
                          Aggravating
                          • systematic pattern of conduct
                          • exports valued at $2,823,000 or more
                          • no compliance program

                          Note: settlement after litigation of a 2014 Penalty Notice (Epsilon v. OFAC, D.C. Cir. 2017).

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Jun 6, 2018Settlement$145,893

                          Ericsson, Inc. and Ericsson AB

                          Manufacturing and trade (telecommunications equipment) · Sudan program · 1 apparent violation · AP or vendor relevant · self-disclosed: yes · egregious: yes

                          FacilitationThird-party or vendor payments

                          Ericsson employees in Sweden and Texas, with a Lebanese subcontractor, bought a US-origin satellite hub for a Sudan network and routed it through Switzerland and Lebanon, agreeing to say the customer was in Botswana if asked. They did so after Ericsson's compliance department said the supply would breach policy, and the final leg to Sudan was never invoiced.

                          “BCom did not issue an invoice to EAB for the final stage of the transaction taking the satellite hub from Lebanon to Sudan”
                          Mitigating and aggravating factors
                          Mitigating
                          • voluntary self-disclosure, thorough internal investigation and tolling
                          • no penalty notice or Finding of Violation in prior five years
                          • remedial response and additional controls
                          • low likelihood of recurrence
                          Aggravating
                          • willful conspiracy with a third-country company to evade the embargo
                          • a manager was involved
                          • ignored compliance department warnings
                          • harm to Sudan program objectives
                          • large sophisticated entity

                          Source: OFAC enforcement release (PDF), Sweden and United States; read Nov. 1, 2026.

                          Dec 6, 2017Settlement$1,220,400

                          Dentsply Sirona Inc.

                          Manufacturing and trade (dental equipment) · Iran program · 37 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

                          Third-party or vendor paymentsFacilitation

                          Two Dentsply subsidiaries exported 37 shipments of dental products to third-country distributors knowing the goods were going to Iran, and kept dealing with the distributors after confirming the re-exports. Supervisors participated and concealed the conduct from the parent.

                          “continued to conduct business with these distributors after receiving confirmation that the distributors had re-exported DII products to Iran”
                          Mitigating and aggravating factors
                          Mitigating
                          • no penalty notice or Finding of Violation in prior five years, though a similar 2001 settlement existed
                          • limited harm because exports were likely licensable
                          • remedial company-wide review
                          • cooperation and 1,104-day tolling
                          Aggravating
                          • willful conduct and concealment of Iranian destination
                          • supervisory personnel participated and hid it from the parent
                          • large sophisticated company

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Nov 17, 2017Settlement$204,277

                          BCC Corporate SA (American Express affiliate)

                          Payments (corporate credit card issuer) · Cuba program · 1,818 apparent violations · not an AP or vendor case · self-disclosed: yes · egregious: no

                          Screening skipped data fieldsNo compliance program

                          Corporate credit cards issued by a Belgian AmEx affiliate were used for 1,818 purchases in Cuba over five years. The issuer screened for SDN name matches but had no control to block card use in a sanctioned country, and no one had assessed that risk.

                          “failed to implement controls to prevent BCCC-issued credit cards from being used in Cuba”
                          Mitigating and aggravating factors
                          Mitigating
                          • no penalty notice or Finding of Violation in prior five years
                          • swift remedial action
                          • voluntary self-disclosure
                          • tolling agreements
                          Aggravating
                          • personnel had reason to know
                          • never assessed the risk of cards being used in Cuba
                          • harm to sanctions program objectives
                          • large sophisticated financial institution
                          • provided inaccurate or incomplete information during the investigation

                          Source: OFAC enforcement release (PDF), Belgium (50 percent US-owned via Alpha Card); read Nov. 1, 2026.

                          Oct 5, 2017Settlement$372,465

                          BD White Birch Investment LLC

                          Manufacturing and trade (paper) · Sudan program · 3 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

                          FacilitationNo compliance program

                          US personnel of White Birch helped arrange and execute two shipments of Canadian paper from its Canadian subsidiary to Sudan, and Canadian staff tried to hide the destination from the US confirming bank on a letter of credit. OFAC stressed that foreign subsidiaries must act independently of US parents in sanctioned-country business.

                          “attempted to conceal the ultimate destination of the goods from its bank”
                          Mitigating and aggravating factors
                          Mitigating
                          • no prior OFAC sanctions history
                          • remedial steps including new policies and company-wide training
                          Aggravating
                          • reckless disregard
                          • attempted concealment of destination from US confirming bank
                          • supervisors had actual knowledge
                          • large sophisticated company
                          • compliance program non-existent or inadequate
                          • submitted inaccurate or misleading information to OFAC

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Sep 26, 2017Settlement$334,800

                          Richemont North America, Inc., d.b.a. Cartier

                          Other: luxury retail · Narcotics program · 4 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

                          No screening performedCustomer or counterparty due diligence

                          Cartier boutiques shipped four jewelry purchases to Shuen Wai Holding in Hong Kong, an SDN, after a buyer gave that company's exact name and address as the ship-to party. The ship-to details matched the SDN List entry but no sanctions check caught it before shipment.

                          “contained the same name, address, and country location for Shuen Wai as they appear on the SDN List”
                          Mitigating and aggravating factors
                          Mitigating
                          • no penalty notice or Finding of Violation in prior five years
                          • cooperation including multiple tolling agreements
                          • remedial action
                          Aggravating
                          • failed to exercise minimal caution
                          • significant harm by giving an SDN access to the commercial marketplace
                          • sophisticated entity in an industry at high risk for money laundering

                          Note: year table shows 344,800; release text says 334,800.

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Aug 24, 2017Settlement$415,350

                          COSL Singapore Ltd

                          Other: oilfield services · Iran program · 55 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

                          Third-party or vendor paymentsNo compliance program

                          COSL's procurement specialists bought 55 orders of rig supplies from US vendors for re-export to four rigs operating in Iranian waters. Some US vendor quotations carried warnings against re-export to Iran, yet the purchases continued for years with no OFAC compliance program.

                          “procurement specialists purchased at least 55 orders of supplies from vendors located in the United States”
                          Mitigating and aggravating factors
                          Mitigating
                          • no prior sanctions history
                          • instituted an OFAC compliance program
                          • substantial cooperation and tolling agreement
                          Aggravating
                          • failed to exercise minimal caution
                          • aided development of Iran's energy resources
                          • large sophisticated company with 14 rigs
                          • no OFAC compliance program despite US business

                          Source: OFAC enforcement release (PDF), Singapore; read Nov. 1, 2026.

                          Aug 17, 2017Settlement$518,063

                          American Export Lines (Blue Sky Blue Sea, Inc.)

                          Logistics and freight · Iran program · 140 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: no

                          Facilitation

                          A Los Angeles freight forwarder transshipped used cars and parts from the US through Iran to Afghanistan on 140 occasions. Its compliance program existed but was silent on Iranian transshipment, and the president approved the routing.

                          “transshipping used and junked cars and parts from the United States via Iran to Afghanistan on 140 occasions”
                          Mitigating and aggravating factors
                          Mitigating
                          • goods had no end use in Iran
                          • no prior sanctions history
                          • small business and violations under one percent of shipments
                          • had a compliance program though silent on transshipments
                          • ceased before investigation and amended policy
                          • 804-day tolling
                          Aggravating
                          • reckless disregard
                          • President and co-owner knew and approved
                          • economic benefit to Iran
                          • sophisticated freight forwarder experienced with the ITSR

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Aug 10, 2017Settlement$259,200

                          IPSA International Services, Inc.

                          Other: investigative and due diligence services · Iran program · 72 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

                          Third-party or vendor paymentsFacilitation

                          IPSA's Canadian and Dubai subsidiaries hired subcontractors to perform background checks inside Iran for citizenship-by-investment clients, and the US parent reviewed, approved and initiated the subsidiaries' payments to those Iranian-origin service providers. OFAC treated this as importing Iranian services and facilitating the subsidiaries' dealings.

                          “IPSA reviewed, approved, and initiated the foreign subsidiaries’ payments to providers of the Iranian-origin services”
                          Mitigating and aggravating factors
                          Mitigating
                          • no prior sanctions history
                          • significant remedial measures including new internal controls
                          • substantial cooperation including a voluntary look-back report and tolling
                          Aggravating
                          • failed to exercise minimal caution in approving payments for Iranian-origin services, a pattern over time
                          • senior management knew or had reason to know
                          • economic benefit to Iran and conduct not licensable
                          • sophisticated international company
                          • compliance program did not recognize the risk

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Jul 27, 2017Settlement$12,027,066

                          CSE Global Limited and CSE TransTel Pte. Ltd.

                          Other: telecommunications engineering · Iran program · 104 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: yes

                          Third-party or vendor paymentsFacilitation

                          TransTel paid Iranian and other vendors for its Iranian energy projects with 104 USD wires totaling over $11 million that cleared through US banks, with no reference to Iran in the payment messages. Two months earlier its management had signed a letter undertaking to its bank not to route Iran-related business through it.

                          “None of the transactions contained references to Iran, the Iranian projects, or any Iranian parties”
                          Mitigating and aggravating factors
                          Mitigating
                          • no penalty notice, Finding of Violation or cautionary letter in prior five years
                          • remedial steps
                          • substantial cooperation
                          Aggravating
                          • willful and reckless conduct with systematic obfuscation and a false bank attestation
                          • senior management actively involved
                          • significant economic benefit to Iran's oil, gas and power industries
                          • sophisticated multinational company

                          Source: OFAC enforcement release (PDF), Singapore; read Nov. 1, 2026.

                          Jul 20, 2017Penalty notice$2,000,000

                          ExxonMobil Corporation

                          Other: oil and gas · Ukraine/Russia program · 8 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: yes

                          Customer or counterparty due diligence

                          Presidents of two ExxonMobil subsidiaries signed eight contracts for Russian oil and gas projects with Igor Sechin, the Rosneft president who had been added to the SDN List weeks earlier. OFAC rejected the argument that dealing with an SDN in his professional capacity was permitted and assessed a $2 million penalty.

                          “signing eight legal documents related to oil and gas projects in Russia with Igor Sechin”
                          Mitigating and aggravating factors
                          Mitigating
                          • no penalty notice or Finding of Violation in prior five years
                          Aggravating
                          • reckless disregard of warning signs
                          • senior-most executives knew of the SDN status
                          • significant harm to Ukraine-related program objectives
                          • sophisticated company experienced with sanctions

                          Note: egregiousness not stated in release; statutory maximum assessed.

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Jun 26, 2017Settlement$148,698

                          American International Group, Inc.

                          Insurance · Iran and WMD and Sudan and Cuba programs · 555 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

                          Screening skipped data fieldsCustomer or counterparty due diligence

                          AIG insured cargo shipments to or through Iran, Sudan and Cuba and aboard blocked IRISL vessels, collecting premiums and paying claims in 555 transactions. Its sanctions exclusion clauses were often too narrow or missing, and some insureds bought single-shipment policies to avoid them.

                          “most were too narrow in their scope and application to be effective”
                          Mitigating and aggravating factors
                          Mitigating
                          • no penalty notice or Finding of Violation in prior five years
                          • had a compliance program using exclusion clauses
                          • remedial action
                          • voluntary self-disclosure and cooperation with tolling
                          Aggravating
                          • multi-year pattern of issuing policies and paying claims
                          • economic benefit to sanctioned countries and persons
                          • large sophisticated financial institution

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Jun 8, 2017Settlement$87,255

                          American Honda Finance Corporation

                          Other: auto finance · Cuba program · 13 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

                          Screening skipped data fieldsCustomer or counterparty due diligence

                          Honda's Canadian finance subsidiary approved 13 vehicle leases to the Embassy of Cuba, a customer with Cuba in its name that supplied Cuban government documents. The screening system checked SDN names but did not include the names of comprehensively sanctioned countries, and three leases were approved after the initial self-disclosure.

                          “they did not include the names of countries subject to OFAC-administered comprehensive sanctions in their screening system”
                          Mitigating and aggravating factors
                          Mitigating
                          • no penalty notice or Finding of Violation in prior five years
                          • remedial action including new OFAC policy and systems
                          • voluntary self-disclosure and cooperation
                          • OFAC later licensed the leases
                          Aggravating
                          • had reason to know, especially after its own disclosure
                          • Canadian personnel knew of the Cuban Embassy's involvement
                          • harm to sanctions program objectives
                          • large sophisticated financial institution

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Mar 7, 2017Settlement$100,871,266

                          Zhongxing Telecommunications Equipment Corporation (ZTE)

                          Manufacturing and trade (telecommunications equipment) · Iran program · 251 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: yes

                          Third-party or vendor paymentsFacilitation

                          ZTE's top management ran a company-wide plan using third-party companies to conceal the supply of US-origin goods to Iranian customers, then secretly resumed the business during a US investigation and altered evidence. The settlement ran alongside BIS and DOJ resolutions.

                          “utilized third-party companies to conceal and facilitate ZTE’s illegal business with Iran”
                          Mitigating and aggravating factors
                          Mitigating
                          • no penalty notice or Finding of Violation in prior five years
                          • cooperation including three tolling agreements totaling 803 days and witness interviews after March 2016
                          • remedial steps late in the investigation including a sanctions and export controls compliance program
                          Aggravating
                          • willful and reckless conduct with long-term obfuscation
                          • actual knowledge and management direction
                          • significant harm from high volume of controlled US goods to Iran
                          • large sophisticated company
                          • compliance program non-existent or unenforced

                          Source: OFAC enforcement release (PDF), China; read Nov. 1, 2026.

                          Feb 28, 2017Settlement$515,400

                          United Medical Instruments Inc.

                          Other: medical equipment distributor · Iran program · 56 apparent violations · AP or vendor relevant · self-disclosed: not stated · egregious: not stated

                          FacilitationNo compliance program

                          UMI sold medical imaging equipment at least 56 times knowing it was intended for buyers in Iran and facilitated sales from a UAE company to Iran. OFAC attributed the conduct to a single employee and noted the company had applied for a license in 2003, so it knew one was needed.

                          “UMI failed to effectively manage and enforce its compliance program”
                          Mitigating and aggravating factors
                          Mitigating
                          • conduct of a single employee rather than company-wide
                          • remedial action including ceasing Iran transactions
                          • no penalty notice or Finding of Violation in prior five years
                          • cooperation and tolling agreements
                          • small business
                          • financial difficulties
                          Aggravating
                          • willful exports with prior notice
                          • actual knowledge that a license was required
                          • failed to manage and enforce its compliance program

                          Note: not stated in release; settlement largely satisfied by compliance with a 2013 BIS settlement, with $15,400 paid to Treasury.

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Jan 13, 2017Settlement$516,105

                          Toronto-Dominion Bank

                          Banking · Cuba and Iran programs · 167 apparent violations · not an AP or vendor case · self-disclosed: yes · egregious: no

                          No screening performedCustomer or counterparty due diligence50 Percent Rule missed

                          TD Bank's trade finance unit did not screen letters of credit for sanctions nexus, and the bank kept accounts for a Canadian company owned by a Cuban company, a freight business listed as sales agent for an Iranian SDN, and 62 Cuban nationals, processing 167 USD transactions through the US. Employees and compliance staff knew of the Cuban ownership and of the procedural gap.

                          “the bank failed to screen for any potential nexus to an OFAC-sanctioned country or entity”
                          Mitigating and aggravating factors
                          Mitigating
                          • no managers had actual knowledge of the Pars Marine and retail customer conduct
                          • Cuban national customers were licensable and later covered by a general license
                          • voluntary self-disclosure and cooperation
                          • remedial action
                          Aggravating
                          • compliance and management staff knew of USD transactions for a Cuban entity and the gap permitting them
                          • personnel had reason to know from documents in the bank's possession
                          • large sophisticated global institution
                          • controls insufficient to identify customers owned by or doing business with sanctioned countries

                          Source: OFAC enforcement release (PDF), Canada; read Nov. 1, 2026.

                          Jan 13, 2017Finding of violationno penalty

                          Toronto-Dominion Bank (Internaxx Bank SA and TD Waterhouse Investment Services (Europe))

                          Banking (online brokerage) · Iran and Cuba programs · 3,491 apparent violations · not an AP or vendor case · self-disclosed: not stated · egregious: not stated

                          No compliance programCustomer or counterparty due diligenceGeolocation or IP data ignored

                          TD's Luxembourg online broker Internaxx opened and kept accounts for customers resident in Iran or Cuba and, with TD Waterhouse, executed 3,491 US securities trades worth about $93 million for them. Internaxx had no OFAC program or controls to identify customers in sanctioned countries until October 2011.

                          “the risk associated with online payment platforms when the financial institution is unable to restrict access”
                          Mitigating and aggravating factors
                          Mitigating
                          • not a pattern of misconduct but insufficient policies
                          • Cuba harm limited to one diplomat
                          • small institution
                          • no penalty notice or Finding of Violation in prior five years
                          • remedial action through TD Bank
                          Aggravating
                          • had information showing customers were in sanctioned countries and shared it before trading
                          • large volume over several years
                          • no OFAC compliance program until October 2011

                          Note: Finding of Violation, no monetary penalty.

                          Source: OFAC enforcement release (PDF), Canada (Luxembourg and UK subsidiaries); read Nov. 1, 2026.

                          Jan 12, 2017Settlement$10,000

                          An Individual and the Alliance for Responsible Cuba Policy Foundation

                          Other: nonprofit and individual · Cuba program · violation count not stated · not an AP or vendor case · self-disclosed: no · egregious: not stated

                          An individual acting as an officer of a small nonprofit made two unauthorized business trips to Cuba and arranged travel for 20 others, after receiving an OFAC cautionary letter for similar travel. The foundation paid $10,000.

                          “having been issued a cautionary letter from OFAC prior to the aforementioned trips”
                          Mitigating and aggravating factors
                          Mitigating
                          • minimal harm to current Cuba program objectives
                          • individual and small nonprofit
                          • financial condition
                          Aggravating
                          • willful conduct after a cautionary letter
                          • knowingly facilitated others' unauthorized travel

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Jan 12, 2017Settlement$17,500

                          Aban Offshore Limited

                          Other: offshore drilling · Iran program · 1 apparent violation · AP or vendor relevant · self-disclosed: no · egregious: no

                          Third-party or vendor paymentsNo compliance program

                          Aban's Singapore subsidiary ordered $10,127 of rig supplies from a US vendor for re-export through the UAE to a rig in Iran's South Pars field. The company had no OFAC compliance program despite doing business with US suppliers.

                          “placed an order for oil rig supplies from a vendor in the United States with the intended purpose of re-exporting”
                          Mitigating and aggravating factors
                          Mitigating
                          • no prior sanctions history
                          • instituted an OFAC compliance program
                          • substantial cooperation including look-back and 1,134 days of tolling
                          Aggravating
                          • failed to exercise minimal caution
                          • aided development of Iran's energy resources
                          • large sophisticated company
                          • no OFAC compliance program

                          Source: OFAC enforcement release (PDF), India; read Nov. 1, 2026.

                          Nov 14, 2016Settlement$5,976,028

                          National Oilwell Varco, Inc. (with Dreco Energy Services and NOV Elmar)

                          Manufacturing and trade · Iran and Cuba and Sudan programs · 61 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: mixed

                          Third-party or vendor paymentsFacilitationNo compliance program

                          NOV finance executives approved commission payments to a UK agent on sales to Iran while acquiescing to the subsidiary's practice of not naming Iran, and subsidiaries exported goods to Iran, Cuba and Sudan. The OFAC amount was deemed satisfied by a $25 million payment under a non-prosecution agreement.

                          “senior-level finance executives within NOV approved the four commission payments”
                          Mitigating and aggravating factors
                          Mitigating
                          • no penalty notice or Finding of Violation in prior five years
                          • cooperation including tolling for more than 2,600 days
                          • remediation and agreed compliance enhancements
                          Aggravating
                          • reckless disregard
                          • senior managers knew or had reason to know transactions involved Iran
                          • significant sustained economic benefit to petroleum industries in Cuba, Iran and Sudan
                          • large sophisticated company in high-risk regions
                          • wholly inadequate compliance program

                          Note: four Dreco commission payments egregious; remaining apparent violations non-egregious.

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Sep 13, 2016Settlement$4,320,000

                          PanAmerican Seed Company (division of Ball Horticultural)

                          Other: agriculture, seeds · Iran program · 48 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: yes

                          Third-party or vendor paymentsFacilitation

                          PanAm Seed sold flower seeds 48 times to two Iranian distributors by shipping to consignees in Europe and the Middle East who re-exported to Iran. Mid-level managers knew a license was needed and the company obscured the Iranian destination, continuing sales for months after learning of OFAC's investigation.

                          “PanAm Seed engaged in a pattern or practice designed to conceal the involvement of Iran”
                          Mitigating and aggravating factors
                          Mitigating
                          • no penalty notice or Finding of Violation in prior five years
                          • exports likely licensable under TSRA
                          • remedial steps including stopping exports and a compliance program
                          • 882-day tolling agreement
                          Aggravating
                          • willful and systematic obfuscation
                          • recklessness despite substantial international sales and warnings
                          • mid-level managers knew and sales continued after investigation began
                          • over $770,000 economic benefit to Iran over years
                          • initial cooperation was inaccurate or incomplete
                          • division of a sophisticated international corporation

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Sep 7, 2016Settlement$43,200

                          World Class Technology Corporation

                          Manufacturing and trade (orthodontic devices) · Iran program · 7 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

                          Third-party or vendor paymentsNo compliance program

                          WCT exported seven shipments of orthodontic devices to Germany, the UAE and Lebanon knowing they were intended for re-export to Iran. It had no OFAC compliance program until June 2008 and lacked experience in international sales.

                          “with knowledge or reason to know that the shipments were intended specifically for supply, transshipment, or reexportation to Iran”
                          Mitigating and aggravating factors
                          Mitigating
                          • no great economic benefit because transactions were likely licensable
                          • no sanctions history in prior five years
                          • tolling agreement
                          • compliance procedure developed in 2008
                          • lacked commercial sophistication
                          Aggravating
                          • willful violation
                          • management had actual knowledge or reason to know
                          • no OFAC compliance program until June 2008

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Jul 5, 2016Settlement$7,617,150

                          Alcon Laboratories, Inc., Alcon Pharmaceuticals Ltd., and Alcon Management, SA

                          Manufacturing and trade (medical and pharmaceutical) · Iran and Sudan programs · 513 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

                          No compliance programThird-party or vendor paymentsCustomer or counterparty due diligence

                          Alcon exported surgical and pharmaceutical products from the US to distributors in Iran (452 times) and Sudan (61 times) without OFAC licenses, despite the products being licensable. OFAC found it had virtually no compliance program and did not investigate when its freight forwarder stopped shipping to Iran.

                          “having virtually no compliance program, despite significant business involving the exportation of goods from the United States to Iran and Sudan”
                          Mitigating and aggravating factors
                          Mitigating
                          • limited harm because medical products were licensable and had been licensed before
                          • no prior OFAC sanctions history
                          • remedial action including a robust compliance program
                          • substantial cooperation and tolling agreements
                          Aggravating
                          • reckless disregard with virtually no compliance program
                          • failed to investigate freight forwarder's cessation of shipments to Iran
                          • senior management knew
                          • sophisticated multinational

                          Source: OFAC enforcement release (PDF), United States and Switzerland; read Nov. 1, 2026.

                          Jun 23, 2016Settlement$107,691

                          HyperBranch Medical Technology, Inc.

                          Manufacturing and trade (medical devices) · Iran program · 2 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

                          Third-party or vendor paymentsNo compliance program

                          HyperBranch shipped surgical sealants to its UAE distributor knowing they were headed to Iran, edited its destination control statement at the distributor's request, and kept doing business after confirming the re-exports. The former CEO and international sales manager knew.

                          “editing its destination control statement at the request of its distributor”
                          Mitigating and aggravating factors
                          Mitigating
                          • limited harm because medical products were likely licensable
                          • no prior OFAC sanctions history
                          • remedial steps including an OFAC compliance program
                          • cooperation and 513-day tolling
                          Aggravating
                          • willful conduct including editing the destination control statement
                          • former CEO and sales manager knew
                          • no sanctions compliance program

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Feb 25, 2016Settlement$304,706

                          Halliburton Atlantic Limited and Halliburton Overseas Limited

                          Other: oilfield services · Cuba program · 19 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

                          Customer or counterparty due diligenceScreening skipped data fields50 Percent Rule missed

                          Two Cayman subsidiaries invoiced an Angolan consortium operator $1.19 million for oilfield goods and services in a concession where Cuba's state oil company held a five percent interest. OFAC faulted the lack of a procedure to screen all consortium members, since documents the operator supplied showed Cupet as a member.

                          “it did not include a procedure to screen all of the Consortium members”
                          Mitigating and aggravating factors
                          Mitigating
                          • first violation mitigation, no penalty notice or Finding of Violation in prior five years
                          • Cupet's interest was only five percent
                          Aggravating
                          • reckless disregard by not performing due diligence on consortium membership
                          • should have known from operator documents, a news article and a government registry
                          • sophisticated entities
                          • compliance program lacked a procedure to screen all consortium members

                          Source: OFAC enforcement release (PDF), Cayman Islands (US-owned); read Nov. 1, 2026.

                          Feb 22, 2016Settlement$614,250

                          CGG Services S.A. and affiliated companies

                          Other: seismic and oilfield services · Cuba program · 22 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

                          Third-party or vendor paymentsFacilitation

                          CGG France and its US affiliate exported US-origin spare parts and equipment, including goods bought from unaffiliated US suppliers, to survey vessels operating in Cuban waters, and a Venezuelan subsidiary processed seismic data benefiting a Cuban company. The US affiliate had warned that such exports could violate sanctions.

                          “exported U.S.-origin goods from companies unaffiliated with CGG France to the vessel M/V Veritas Vantage while the vessel operated in Cuba’s territorial waters”
                          Mitigating and aggravating factors
                          Mitigating
                          • no penalty notice or Finding of Violation in prior five years
                          • some compliance steps such as removing US personnel before entering Cuban waters
                          • adjusted supply procedures
                          • tolling agreement and substantial cooperation
                          Aggravating
                          • reckless disregard after US affiliate warning
                          • data processing without determining Cuban interest
                          • knew vessel locations and goods origin
                          • substantial economic benefit to Cuba in oil exploration

                          Source: OFAC enforcement release (PDF), France; read Nov. 1, 2026.

                          Feb 8, 2016Settlement$2,485,890

                          Barclays Bank Plc

                          Banking · Zimbabwe program · 159 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: no

                          50 Percent Rule missedScreening skipped data fieldsLegacy or unintegrated systemCustomer or counterparty due diligence

                          Barclays processed 159 USD transactions for Zimbabwean corporate customers owned 50 percent or more by the SDN Industrial Development Corporation of Zimbabwe. The Zimbabwe unit's customer system could not capture beneficial owners, so UK screening that relied on that data never saw the ownership, and even after an internal investigation confirmed it the bank failed to load the party into its filter promptly.

                          “prevented BBZ from accurately capturing and/or screening beneficial ownership information for its corporate customers”
                          Mitigating and aggravating factors
                          Mitigating
                          • no prior penalty notice or Finding of Violation
                          • remedial action
                          • cooperation
                          Aggravating
                          • processed transactions for blocked persons over five years
                          • failed to load blocked person into filter after confirming ownership
                          • large sophisticated institution

                          Source: OFAC enforcement release (PDF), United Kingdom; read Nov. 1, 2026.

                          Jan 20, 2016Settlement$140,400

                          WATG Holdings, Inc. and Wimberly Allison Tong and Goo (UK) Limited

                          Other: architecture and design · Cuba program · 3 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

                          No compliance programCustomer or counterparty due diligence

                          WATG's UK subsidiary contracted to design a hotel in Cuba and accepted three payments totaling $284,515 from a Qatari client, plus a write-off of part of the fee. The company had no OFAC compliance program at the time.

                          “received three payments from a Qatari company, from on or about October 13, 2009 to on or about May 20, 2010, totaling $284,515”
                          Mitigating and aggravating factors
                          Mitigating
                          • no prior sanctions history
                          • remedial action including compliance review, compliance officer, global training
                          • 877-day tolling agreement
                          Aggravating
                          • senior managers at the UK unit performed the work
                          • significant harm by supporting Cuba's tourism industry
                          • relatively large sophisticated multinational
                          • no OFAC compliance program

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Nov 24, 2015Settlement$38,930

                          Barracuda Networks, Inc.

                          Software · Iran and Sudan and Syria programs · violation count not stated · AP or vendor relevant · self-disclosed: yes · egregious: no

                          No compliance programGeolocation or IP data ignoredThird-party or vendor paymentsNo screening performed

                          Barracuda's UK subsidiary sold web filtering and security products and subscriptions through resellers and distributors to customers in Iran and Sudan and to Syrian SDNs, and the US parent supplied firmware updates. The company had no written sanctions policy, did not screen the IP addresses contacting its servers, and SDN names appeared on sales invoices.

                          “Barracuda did not screen IP addresses used to contact Barracuda’s servers because it had no OFAC compliance program in place”
                          Mitigating and aggravating factors
                          Mitigating
                          • no prior OFAC penalty notice or Finding of Violation in prior five years
                          • significant remedial steps including Office of Trade Compliance and ability to disable products in sanctioned countries
                          • substantial cooperation including tolling agreement
                          Aggravating
                          • reckless disregard by letting distributors and resellers sell to SDNs and sanctioned countries
                          • knew or had reason to know from IP addresses and invoices
                          • potential significant harm because products could censor internet activity
                          • no OFAC compliance program and no IP screening

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Nov 4, 2015Settlement$139,500

                          Banco do Brasil, S.A., New York Branch

                          Banking · Iran program · 7 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: no

                          Alerts cleared wronglyName matching false negative

                          The branch put a Brazilian carpet importer named Isfahan on a 'Good Guy Exception List' after repeated filter alerts on the word Isfahan, relying on verbal assurances, and then processed funds transfers that paid for Iranian-origin goods. Even after a US intermediary rejected one payment for Iran involvement, the branch released three more.

                          “risks associated with a false hit list that was not reviewed and updated regularly”
                          Mitigating and aggravating factors
                          Mitigating
                          • no prior penalty notice or Finding of Violation
                          • appropriate remedial action
                          • substantial cooperation including identifying four of the seven apparent violations
                          Aggravating
                          • employees failed to exercise minimal caution including reliance on a partially illegible invoice
                          • staff and a Senior Compliance Officer knew of the conduct
                          • four transactions provided economic benefit to Iran

                          Source: OFAC enforcement release (PDF), Brazil (New York branch); read Nov. 1, 2026.

                          Oct 27, 2015Settlement$43,875

                          Gil Tours Travel, Inc.

                          Travel · Cuba program · violation count not stated · not an AP or vendor case · self-disclosed: no · egregious: not stated

                          No compliance program

                          A Philadelphia travel agency provided Cuba travel services for 191 people without OFAC authorization. It had no sanctions compliance plan and some awareness the conduct could violate the Cuba regulations.

                          “Gil Travel had no sanctions compliance plan at the time of the apparent violations”
                          Mitigating and aggravating factors
                          Mitigating
                          • no penalty notice or Finding of Violation in prior five years
                          • substantial cooperation including 446-day tolling agreement
                          Aggravating
                          • some awareness that conduct could violate the CACR
                          • no sanctions compliance plan

                          Note: Cuba Penalty Schedule case, egregiousness not stated.

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Oct 20, 2015Settlement$329,593,585

                          Crédit Agricole Corporate and Investment Bank

                          Banking · Sudan and Cuba and Burma and Iran programs · 4,297 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: yes

                          FacilitationScreening skipped data fields

                          CA-CIB and its Swiss subsidiary used cover payments and special payment practices that stripped references to sanctioned parties from USD SWIFT messages sent to US banks, mostly involving Sudan. The settlement was part of a global resolution with DOJ, the Manhattan DA, the Federal Reserve and NYDFS.

                          “omitted references to U.S.-sanctioned parties in U.S. Dollar (USD) Society for Worldwide Interbank Financial Telecommunication (SWIFT) payment messages”
                          Mitigating and aggravating factors
                          Mitigating
                          • no penalty notice or Finding of Violation in prior five years
                          • appropriate remedial action
                          • substantial cooperation including tolling agreements
                          • most conduct predated the ABN Amro settlement
                          Aggravating
                          • indications that conduct might violate US law before the earliest violation
                          • managers in Swiss locations and Paris head office were aware
                          • significant harm to several sanctions programs
                          • large sophisticated institution
                          • inadequate controls and compliance program

                          Source: OFAC enforcement release (PDF), France; read Nov. 1, 2026.

                          Aug 27, 2015Settlement$1,700,100

                          UBS AG

                          Banking · SDN/counterterrorism program · 222 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: no

                          Screening skipped data fieldsLegacy or unintegrated system

                          UBS processed 222 US securities transactions for a Zurich client who was an SDGT because its screening covered only external funds transfers and treated securities bookings as internal transfers. The client's name appeared only in internal account entries, so no alert was generated for years.

                          “UBS considered the securities-related transactions to be internal transfers since they did not involve external parties”
                          Mitigating and aggravating factors
                          Mitigating
                          • no prior penalty notice or Finding of Violation
                          • remedial action
                          • cooperation
                          Aggravating
                          • reckless disregard despite numerous warning signs
                          • management and compliance staff had actual knowledge
                          • economic benefit to a Specially Designated Global Terrorist
                          • large sophisticated institution

                          Source: OFAC enforcement release (PDF), Switzerland; read Nov. 1, 2026.

                          Aug 6, 2015Settlement$271,815

                          Navigators Insurance Company

                          Insurance · North Korea and Iran and Sudan and Cuba programs · 48 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

                          No compliance programCustomer or counterparty due diligence

                          Navigators and its London branch wrote P&I policies covering North Korean-flagged vessels and incidents in Iran, Sudan and Cuba, collecting premiums and paying claims. It had no formal OFAC program and UK staff misread the reach of US sanctions.

                          “Navigators did not have a formal OFAC compliance program in place at the time it engaged in these apparent violations”
                          Mitigating and aggravating factors
                          Mitigating
                          • no penalty notice or Finding of Violation in prior five years
                          • remedial action including a comprehensive OFAC program
                          • cooperation and tolling agreement
                          Aggravating
                          • managers knew or had reason to know policies and claims involved sanctioned countries
                          • commercially sophisticated
                          • no formal OFAC compliance program

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Aug 5, 2015Settlement$78,750

                          Production Products, Inc.

                          Manufacturing and trade · WMD program · 2 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

                          No screening performedNo compliance programCustomer or counterparty due diligence

                          A ten-employee manufacturer shipped three duct fabrication machines worth $500,000 to China National Precision Machinery Import and Export Corp., an SDN, and accepted payment. It had no sanctions compliance program and knew who the customer was.

                          “PPI had knowledge that the transaction involved CNPM, a Specially Designated National”
                          Mitigating and aggravating factors
                          Mitigating
                          • no penalty notice or Finding of Violation in prior five years
                          • small family-owned business with ten employees
                          • remedial steps to implement a program
                          • substantial cooperation
                          Aggravating
                          • failed to exercise minimal caution
                          • knew the transaction involved an SDN
                          • no sanctions compliance program
                          • economic benefit to an SDN

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Jul 29, 2015Penalty notice$82,260

                          Blue Robin, Inc.

                          Software · Iran program · 33 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: no

                          Third-party or vendor paymentsNo compliance program

                          Blue Robin imported web development services in 33 transactions from an Iranian vendor, PersiaBME, paying $205,650 over the period. It had no OFAC program and kept receiving technical assistance after learning the conduct was prohibited.

                          “imported Web development services valued at $205,650 from an Iranian company called PersiaBME”
                          Mitigating and aggravating factors
                          Mitigating
                          • no prior OFAC sanctions history
                          • small business claiming financial difficulties
                          • substantial cooperation including 541-day tolling
                          Aggravating
                          • reckless conduct with a company known to be in Iran
                          • co-owner and manager knew
                          • economic benefit to an Iranian company
                          • continued receiving services after awareness
                          • no compliance program then or since
                          • limited remedial response

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Jul 24, 2015Settlement$214,000

                          Great Plains Stainless Co.

                          Other: steel distributor · WMD program · 2 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

                          Third-party or vendor paymentsNo compliance program

                          A Tulsa steel company sold goods that its Chinese vendor shipped to a Dubai customer aboard a vessel blocked under the WMD proliferators program, then had new trade documents created with the vessel reference removed to get the goods released. OFAC treated the altered documents as an attempt to evade the prohibitions.

                          “requested the creation of new trade documents, with references to the blocked vessel removed”
                          Mitigating and aggravating factors
                          Mitigating
                          • no penalty notice or Finding of Violation in prior five years
                          • no reason to know a blocked vessel would be used until sailing date
                          • small company
                          • remedial measures
                          Aggravating
                          • willful conduct in obtaining an altered bill of lading
                          • disregarded OFAC verbal and written guidance
                          • aware conduct required a license because it had applied for one
                          • no compliance program

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Jun 19, 2015Settlement$391,950

                          John Bean Technologies Corporation

                          Manufacturing and trade · WMD and Iran programs · 3 apparent violations · AP or vendor relevant · self-disclosed: no · egregious: no

                          Third-party or vendor paymentsNo screening performed

                          Goods JBT sold to a Chinese buyer were shipped by IRISL on a blocked vessel, and JBT presented the trade documents to a US bank and then a Spanish bank to collect a $2.9 million letter of credit. JBT also reimbursed its Spanish affiliate for freight forwarder charges paid for the IRISL shipping services.

                          “reimbursed JBT AeroTech Spain for charges paid to its freight forwarder for the shipping services rendered by IRISL”
                          Mitigating and aggravating factors
                          Mitigating
                          • no penalty notice or Finding of Violation in prior five years
                          • remedial measures including training and enhanced party screening
                          • cooperation including 514-day tolling
                          Aggravating
                          • management knew of the conduct for counts 2 and 3
                          • economic benefit to a blocked entity
                          • sophisticated global company

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Jun 18, 2015Settlement$28,800

                          National Bank of Pakistan, New York Branch

                          Banking · SDN/counterterrorism program · 7 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: no

                          Name matching false negative

                          The New York branch processed seven funds transfers for the account of Kyrgyz Trans Avia, an airline designated as an SDGT, held at the bank's Bishkek branch. The interdiction filter never generated an alert on the SDN name.

                          “NBP New York’s OFAC interdiction filter failed to generate an alert or identify any potential matches”
                          Mitigating and aggravating factors
                          Mitigating
                          • no managers or supervisors aware
                          • no penalty notice or Finding of Violation in prior five years
                          • remedial action and filter enhancements
                          • cooperation
                          Aggravating
                          • seven transactions with an SDN, five conferring economic benefit
                          • sophisticated financial institution
                          • filter failed to alert on an SDN in seven separate transactions

                          Source: OFAC enforcement release (PDF), Pakistan (New York branch); read Nov. 1, 2026.

                          Apr 15, 2015Settlement$23,336

                          First Data Resources, LLC

                          Payments · Narcotics program · violation count not stated · AP or vendor relevant · self-disclosed: yes · egregious: no

                          Alerts cleared wronglyCustomer or counterparty due diligence

                          First Data provided third-party data processing services to a Specially Designated Narcotics Trafficker for about four months after its interdiction software flagged the party as a potential match. The program miscategorized potential SDN matches, and a client was able to reactivate the trafficker's access after First Data had cut it off.

                          “incorrectly categorized potential matches to OFAC’s List of Specially Designated Nationals and Blocked Persons”
                          Mitigating and aggravating factors
                          Mitigating
                          • no prior sanctions history in five years
                          • remedial action to fix match categorization
                          • cooperation
                          Aggravating
                          • failed to exercise minimal caution in reviewing flagged information
                          • had reason to know from the first software flag
                          • significant harm by conveying economic benefit to an SDNT
                          • highly sophisticated entity

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Mar 25, 2015Settlement$7,658,300

                          PayPal, Inc.

                          Payments · WMD and Iran and Cuba and SDN/counterterrorism and Sudan programs · 486 apparent violations · AP or vendor relevant · self-disclosed: yes · egregious: mixed

                          No screening performedAlerts cleared wronglyName matching false negativeCustomer or counterparty due diligence

                          PayPal did not screen in-process transactions for years, so payments referencing Tehran, Khartoum, Cuba or Iran and accounts tied to SDGTs went through. Its filter also missed a WMD-designated customer for six months, and agents then dismissed six successive alerts on his account, once even after his passport matched the SDN's date and place of birth.

                          “PayPal did not screen in-process transactions in order to reject or block prohibited transactions”
                          Mitigating and aggravating factors
                          Mitigating
                          • voluntary self-disclosure
                          • remedial action
                          • cooperation
                          Aggravating
                          • reckless disregard in operating a payment system without appropriate controls
                          • filter failed to identify the SDN for six months
                          • agents cleared name matches six times ignoring warning signs
                          • economic benefit to an SDN
                          • agents failed to follow escalation procedures

                          Note: WMDPSR violations egregious; ITSR, CACR, GTSR and SSR violations non-egregious.

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Mar 25, 2015Settlement$780,000

                          Life For Relief and Development

                          Other: nonprofit · Iraq program · 4 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: yes

                          Facilitation

                          A Michigan charity formed a conspiracy in 2002 and 2003 to move funds to Iraq through Jordan despite written notice from OFAC that such transfers were prohibited. The settlement was part of a DOJ resolution.

                          “knowingly and willfully formed a conspiracy for the purpose of transferring funds from the United States to Iraq”
                          Mitigating and aggravating factors
                          Mitigating
                          • no prior OFAC sanctions history
                          • remedial response and agreement to build an OFAC program
                          • waived statute of limitations
                          • settlement part of DOJ cooperation agreement
                          Aggravating
                          • willful conduct
                          • written notice from OFAC beforehand
                          • President directed the transfers
                          • funds reached Iraq

                          Source: OFAC enforcement release (PDF), United States; read Nov. 1, 2026.

                          Mar 12, 2015Settlement$258,660,796

                          Commerzbank AG

                          Banking · Iran and Sudan and WMD and Burma and Cuba programs · 1,596 apparent violations · not an AP or vendor case · self-disclosed: no · egregious: yes

                          FacilitationScreening skipped data fields

                          Commerzbank stripped references to Iranian banks and other sanctioned parties from SWIFT messages sent to US banks and routed Iranian payments to a manual queue to avoid automated screening. The OFAC settlement was satisfied by payments under the DOJ and Manhattan DA resolutions.

                          “payment practices that removed, omitted, obscured, or otherwise failed to include references”
                          Mitigating and aggravating factors
                          Mitigating
                          • no penalty notice or Finding of Violation in prior five years
                          • cooperation including extensive internal investigation and tolling
                          • remedial action
                          Aggravating
                          • at least reckless disregard
                          • management knew or had reason to know
                          • significant economic benefit to sanctioned persons
                          • large sophisticated institution
                          • inadequate policies and procedures

                          Source: OFAC enforcement release (PDF), Germany; read Nov. 1, 2026.

                          How to read the cards

                          Each card is one OFAC enforcement action, as OFAC lists it on its Civil Penalties and Enforcement Information page, taken from the enforcement release OFAC published for it. The date, entity, penalty amount, number of apparent violations, the sanctions programs, and whether OFAC treated the case as egregious and as voluntarily self-disclosed are as the release states them. The summary, the mitigating and aggravating lists and the tags are this site’s paraphrase and coding; the one quotation on each card is copied from the release. Where a release says nothing about egregiousness or self-disclosure (older Cuba cases on the Cuba Penalty Schedule, and Findings of Violation) the card says not stated.

                          OFAC counts actions by table row; this page keeps 179 records from 173 rows because it splits a few releases that resolved separate matters into separate records (UniCredit’s three settlements of April 15, 2019; Standard Chartered’s two of April 9, 2019; Acteon’s two of April 11, 2019; the two Deutsche Bank Trust Company Americas matters of September 9, 2020; the two TD Bank, N.A. matters of December 23, 2021) and keeps Murad LLC and its former executive (May 17, 2023) as one record although OFAC counts two settlements. Penalty amounts are the figures OFAC announced, including where OFAC deemed the amount satisfied by a payment to the Department of Justice or the Bureau of Industry and Security. Findings of Violation carry no penalty and are shown as $0.

                          The 12 actions that are not settlements, 7 penalty notices and 5 Findings of Violation, and the seven actions against individuals are included; use the type and industry filters to set them aside. They matter less to an accounts payable team than the company cases but they show where OFAC has gone since 2024: trustees, property managers, investment advisers, a school, and individuals who paid or were paid by sanctioned parties.

                          By year

                          YearActionsAnnounced penaltiesAP or vendor relevant
                          201515$599,705,9978
                          20169$21,609,3158
                          201717$119,517,84512
                          20188$71,510,5616
                          201926$1,289,027,05915
                          202016$23,565,65711
                          202120$20,896,73913
                          202216$42,664,0077
                          202316$1,541,380,2349
                          202412$48,790,40410
                          202514$265,746,8199
                          2026 (to Oct 27, 2026)10$297,513,2856
                          Total179$4,341,927,922114

                          The dollar totals are dominated by a few bank settlements for payment stripping (Commerzbank 2015, Crédit Agricole 2015, UniCredit and Standard Chartered 2019, Binance 2023, and the 2026 Bank of America and related actions). The 114 AP or vendor relevant actions account for $1.33 billion, about 31 percent of the dollars but 64 percent of the actions; the median penalty across all actions with a penalty is $662,853.

                          The what failed vocabulary

                          Eleven tags, applied from the facts in each release. A case usually carries several. The last two columns count all actions and the AP or vendor relevant subset.

                          TagApplied whenAllAP
                          Third-party or vendor paymentsthe conduct ran through a distributor, reseller, supplier, agent, broker, intermediary or third-party payer, or involved paying or being paid by a blocked or sanctioned-country counterparty8282
                          Customer or counterparty due diligenceknow-your-customer, ownership or end-user checks were missing or incomplete, including after an acquisition8158
                          Facilitationa U.S. person approved, referred, structured or routed a foreign transaction, or a non-U.S. person caused U.S. banks to process payments by stripping or omitting references6948
                          Screening skipped data fieldsscreening existed but did not look at a field that carried the match: address, country, bank identifier, email, IP address, owner, existing customers after a list update5524
                          No compliance programthe release says the respondent had no formal sanctions compliance program, or none that covered the business line5237
                          50 Percent Rule missedthe counterparty was not listed but was owned 50 percent or more by blocked persons, and nobody checked ownership2416
                          Alerts cleared wronglythe filter alerted and a person released the transaction, or a rule auto-released it2112
                          Geolocation or IP data ignoredthe respondent held IP, address or travel data showing a sanctioned location and did not act on it206
                          Legacy or unintegrated systeman old, vendor-supplied or unconnected system did not carry the control the main system had184
                          No screening performedthe transaction type or party was never screened at all1614
                          Name matching false negativethe name was on the list but the matching logic did not return it: case, punctuation, acronyms, hyphens, transliteration, all-word matching158

                          The tags follow the root causes in OFAC’s Framework for OFAC Compliance Commitments (May 2, 2019) where they can: “Sanctions Screening Software or Filter Faults” maps to the screening and matching tags, “Improper Due Diligence on Customers/Clients” to customer or counterparty due diligence and the 50 Percent Rule, “Facilitating Transactions by Non-U.S. Persons” to facilitation, and “Lack of a Formal OFAC SCP” to no compliance program. The sanctions screening guide works through what the pattern means for a payer.

                          Method and caveats

                          • Coverage. Every action on OFAC’s year pages for 2015 to 2025 and on the current-year page as of Nov. 1, 2026. Actions before 2015 are not included. OFAC’s separate settlement agreement PDFs were not used; the enforcement release is the only source for each card.
                          • Two amount discrepancies. OFAC’s 2017 table shows the Richemont North America (Cartier) settlement at $344,800; the release text says $334,800. OFAC’s 2023 table shows Construction Specialties at $660,954; the release text says $660,594. This page uses the release text in both cases, so the 2017 and 2023 totals above are $10,000 and $360 below OFAC’s table totals.
                          • Programs. The Syria program was revoked by Executive Order 14312 effective July 1, 2025, and the comprehensive Sudan program by Executive Order 13761 as amended by Executive Order 13804, effective October 12, 2017. The Syria and Sudan cases are kept as history of how programs fail, not as a statement of what is prohibited today.
                          • The current year is partial. 2026 runs to Oct 27, 2026 and will be extended as OFAC publishes.
                          • Coding is a judgment. Tags, industry and the AP flag were applied by reading each release once; an editor should expect a few borderline calls.

                          Questions people ask

                          Why does the page open with the AP or vendor filter on?

                          Because this site is written for payers. The filter keeps the 114 actions in which the respondent paid, or was paid by, or sold to a sanctioned party, directly or through a distributor, agent or third-party payer. Switch it off to see the bank wire-stripping cases, the platform access cases and the individual cases too.

                          Does a penalty amount mean the company paid that much?

                          Not always. Several settlements were deemed satisfied by payments the company made to the Department of Justice or the Commerce Department in a parallel resolution. The amount shown is the settlement amount OFAC announced; the release says whether it was offset.

                          What is a Finding of Violation?

                          An OFAC determination that a violation occurred, issued without a monetary penalty, under the Economic Sanctions Enforcement Guidelines in Appendix A to 31 CFR part 501. The five on this page carry $0 but the release reads like any other: facts, failures, aggravating and mitigating factors.

                          Can I cite this page?

                          Cite the OFAC release the card links to. This page is an index with an editorial reading of each release; the release is the record.

                          How current is it?

                          Through OFAC’s page as of Nov. 1, 2026, with the last action dated Oct 27, 2026. The page is refreshed from OFAC’s listing; the date on each card is the date OFAC gives in its table.