Sanctions Evasion Reference

Enforcement cases

An enforcement case is a documented instance in which a sanctions or export control violation was established and a consequence imposed. This database holds 87, each sourced to the penalty notice or court record.

cases written up

87

ofac penalty records

287

total penalties since 2009

$7.9bn

timeline

by year

The narrative pages below are written from the enforcement documents themselves — penalty notices, enforcement releases and court records — rather than from press coverage of them. Each one links to the document it is drawn from.

The chart is a different thing: it is the whole published OFAC civil penalties record from 2009–2026, 287 actions, pulled directly from Treasury's own yearly tables. It is not limited to the cases written up here.

OFAC civil penalties and settlements by year, 2009 to 2026. 287 published actions totalling $7.9bn. Source: OFAC Civil Penalties and Enforcement Information, fetched by this site's own ingest.
0 $500m $1.0bn $1.5bn $2.0bn 2009: $772m across 26 actions. Largest: Credit Suisse AG. 09 2010: $201m across 27 actions. Largest: Barclays Bank PLC. 2011: $92m across 21 actions. Largest: JPMorgan Chase Bank N.A.. 11 2012: $1.1bn across 16 actions. Largest: ING Bank N.V.. 2013: $137m across 27 actions. Largest: Weatherford International Ltd.. 13 2014: $1.2bn across 20 actions. Largest: BNP Paribas SA. 2015: $600m across 15 actions. Largest: Crédit Agricole Corporate and Investment Bank. 15 2016: $22m across 9 actions. Largest: Alcon Laboratories, Inc., Alcon Pharmaceuticals Ltd., and Alcon Management, SA. 2017: $119m across 13 actions. Largest: Zhongxing Telecommunications Equipment Corporation. 17 2018: $72m across 8 actions. Largest: Société Générale S.A.. 2019: $1.3bn across 17 actions. Largest: Standard Chartered Bank. 19 2020: $24m across 15 actions. Largest: Société Internationale de Télécommunications Aéronautiques SCRL. 2021: $17m across 13 actions. Largest: Union de Banques Arabes et Françaises. 21 2022: $41m across 12 actions. Largest: Bittrex, Inc.. 2023: $1.5bn across 14 actions. Largest: Binance. 23 2024: $49m across 10 actions. Largest: SCG Plastics Co., Ltd.. 2025: $266m across 14 actions. Largest: GVA Capital Ltd.. 25 2026: $298m across 10 actions. Largest: Adani Enterprises Limited.
The same figures as a table
YearActions TotalLargest single action
2026 10 $298m Adani Enterprises Limited $275m
2025 14 $266m GVA Capital Ltd. $216m
2024 10 $49m SCG Plastics Co., Ltd. $20m
2023 14 $1.5bn Binance $969m
2022 12 $41m Bittrex, Inc. $24m
2021 13 $17m Union de Banques Arabes et Françaises $8.6m
2020 15 $24m Société Internationale de Télécommunications Aéronautiques SCRL $7.8m
2019 17 $1.3bn Standard Chartered Bank $657m
2018 8 $72m Société Générale S.A. $54m
2017 13 $119m Zhongxing Telecommunications Equipment Corporation $101m
2016 9 $22m Alcon Laboratories, Inc., Alcon Pharmaceuticals Ltd., and Alcon Management, SA $7.6m
2015 15 $600m Crédit Agricole Corporate and Investment Bank $330m
2014 20 $1.2bn BNP Paribas SA $964m
2013 27 $137m Weatherford International Ltd. $91m
2012 16 $1.1bn ING Bank N.V. $619m
2011 21 $92m JPMorgan Chase Bank N.A. $88m
2010 27 $201m Barclays Bank PLC $176m
2009 26 $772m Credit Suisse AG $536m

Cases written up on this site

87 cases

Outcome Authority
Adani Enterprises: 35 cargoes of LPG that were not Omani 2023–2026 Settlement OFAC 2026-05-18 $275,000,000
Citibank London: 970 payments, one missed prefix 2022–2026 Civil penalty OFSI 2026-08-11 £4,732,831
Insurance against a risk the seller creates 2026 Designation — — —
Deutsche Bank London: a screening list with no ownership data 2022–2026 Settlement OFSI 2026-04-30 £165,000
Sabre: a $200 test payment through a second bank 2022–2026 Settlement OFSI 2026-05-26 £1,000,921
Keystone Shipping: Russian bitumen via sham sales chains 2023–2026 Criminal conviction Harju County Court (Estonia) 2026-01-21 €250,000
A €62,000 car declared at €4,900 2023–2026 Criminal conviction Viru County Court (Estonia) 2025-08-14 €3,000
Lübeck: 16,000 deliveries to Russian defence companies alleged 2022–2026 Charged, pending — — —
IMG Academy: tuition paid by third parties for two designated parents 2018–2026 Settlement OFAC 2026-02-12 $1,720,000
Apple Distribution International: an ownership change nobody caught 2022–2026 Civil penalty OFSI 2026-03-19 £390,000
Family International Realty: transferred to relatives 2018–2025 Settlement OFAC 2025-01-16 $1,076,923
Flighttime: a false end-user certificate 2022–2025 Charged, pending — — —
GVA Capital: managed through a nephew 2016–2025 Civil penalty OFAC 2025-06-12 $215,988,868
Herbert Smith Freehills Moscow: six payments while closing the office 2022–2025 Civil penalty OFSI 2024-11-11 £465,000
Markom Management: an overpayment returned to a designated person 2018–2025 Civil penalty OFSI 2025-01-10 £300,000
Estonia: a media network kept running after it 'closed' 2020–2025 Criminal conviction Harju County Court (Estonia) 2025-01-27 €7,883
Exodus: support staff who suggested a VPN 2017–2025 Settlement OFAC 2025-12-16 $3,103,360
Gracetown: payments for a designated oligarch's former company 2013–2025 Civil penalty OFAC 2025-12-04 $7,139,305
Haas: unlock codes for machines owned by blocked Russian entities 2019–2025 Settlement OFAC 2025-01-17 $1,044,781
Harman: 'North Dubai' as a code for Iran 2016–2025 Settlement OFAC 2025-07-08 $1,454,145
ShapeShift: 17,183 exchanges with users in sanctioned countries 2016–2025 Settlement OFAC 2025-09-22 $750,000
Herbert Smith Freehills Moscow: six payments in a rushed closure 2022–2025 Civil penalty OFSI 2025-03-14 £465,000
Fracht: a charter on a blocked Mahan Air aircraft 2022–2025 Settlement OFAC 2025-09-03 $1,610,775
Bank of America: the alert rule that suppressed the match 2021–2025 Settlement OFAC 2026-10-13 $11,662,930
TGR Group: cash in one city, USDT in another 2023–2024 Designation — — —
Aiotec: a polypropylene plant declared for Türkiye, delivered to Iran 2015–2024 Settlement OFAC 2024-12-03 $14,550,000
SCG Plastics: Iranian resin with the origin 'Middle East' 2009–2024 Settlement OFAC 2024-04-19 $20,000,000
Netherlands: lab equipment exported through a web of firms 2017–2024 Charged, pending — — —
Mondo TV: paying a North Korean studio through a US company 2019–2024 Settlement OFAC 2024-06-26 $538,000
SkyGeek: a $669 refund to a newly designated UAE supplier 2023–2024 Settlement OFAC 2024-12-31 $22,172
Vietnam Beverage: alcohol to North Korea, paid by 17 firms 2016–2024 Settlement OFAC 2024-10-17 $860,000
C.H. Robinson: five subsidiaries not yet on the parent's screening 2018–2024 Settlement OFAC 2024-12-13 $257,690
EFG: blocked clients behind an omnibus account 2014–2024 Settlement OFAC 2024-03-14 $3,740,442
Interactive Brokers: six failures across one platform 2016–2024 Settlement OFAC 2025-07-15 $11,832,136
Key Holding: found during due diligence for the next sale 2021–2024 Settlement OFAC 2025-07-02 $608,825
Binance: a matching engine with no jurisdiction in it 2017–2023 Settlement OFAC 2023-11-21 $968,618,825
British American Tobacco and the North Korea joint venture 2007–2023 Settlement OFAC 2023-04-25 $508,612,492
Blender, Tornado Cash and Sinbad: designating the mixers 2022–2023 Designation — — —
Lumber Marine and Ice Pearl: the first price cap designations 2022–2023 Designation — — —
Swedbank Latvia: a client banking from Crimea 2015–2023 Settlement OFAC 2023-06-20 $3,430,900
Rotterdam: components invoiced to the Maldives 2022–2023 Criminal conviction Rechtbank Rotterdam 2023-10-31 €200,000
Bittrex: onboarding data collected and not screened 2014–2022 Settlement OFAC 2022-10-11 $24,280,829
Sojitz Hong Kong: dollar payments for Iranian-origin polyethylene 2016–2022 Settlement OFAC 2022-01-11 $5,228,298
Toll Holdings: a freight forwarder's 2,958 payments 2013–2022 Settlement OFAC 2022-04-25 $6,131,855
IPI Partners: a legal opinion built on half the facts 2017–2022 Civil penalty OFAC 2025-12-02 $11,485,352
TradeStation: two layers of geo-blocking, both down 2018–2022 Settlement OFAC 2026-03-17 $1,110,661
Colorcon: 79 Moscow salary payments to designated banks, none screened 2022 Civil penalty OFSI 2025-09-10 £152,750
Extreme Networks: the end user who was named, and the one who was real 2018–2022 Settlement OFAC 2026-10-27 $1,529,685
Nordgas: re-exporting US pressure switches to Iran 2010–2021 Settlement OFAC 2021-03-26 $950,000
Rice Lake Weighing Systems: one email, no translation 2016–2021 Settlement OFAC 2026-08-12 $60,764
Unicat: Iran written as "I" in the emails 2016–2021 Settlement OFAC 2025-06-16 $3,882,797
Essentra FZE: cigarette filters to North Korea through front companies 2018–2020 Settlement OFAC 2020-07-16 $665,112
Standard Chartered UK: 70 loans to a Sberbank subsidiary 2015–2020 Civil penalty OFSI 2020-02-18 £20,471,810
State Street: redated invoices inside an acquisition 2014–2020 Settlement OFAC 2024-07-26 $7,452,501
Berkshire Hathaway: a Turkish subsidiary hid Iran sales 2012–2020 Settlement OFAC 2020-10-20 $4,144,651
Halkbank, Zarrab and Atilla: oil revenue disguised as food 2012–2019 Criminal conviction DOJ 2018-05-16 $0
MID-SHIP Group: payments connected to blocked vessels 2011–2019 Settlement OFAC 2019-05-02 $871,837
Standard Chartered: 9,335 payments from accounts in Dubai 2009–2019 Settlement OFAC 2019-04-09 $657,040,033
ExxonMobil: eight documents signed with Igor Sechin 2014–2019 Civil penalty OFAC 2017-07-20 $2,000,000
Epsilon Electronics: selling to a distributor that sold to Iran 2008–2018 Settlement OFAC 2018-09-13 $1,500,000
Murad: hidden from the acquirer, before and after the deal 2009–2018 Settlement OFAC 2023-05-17 $3,509,286
Bukit Muria Jaya: cigarette paper for North Korea, paid in dollars 2016–2018 Settlement OFAC 2021-01-14 $1,016,000
Payoneer: close matches missed, testing did not notice 2013–2018 Settlement OFAC 2021-07-23 $1,385,901
ZTE: front companies and an internal plan to keep supplying Iran 2010–2017 Criminal conviction OFAC 2017-03-07 $100,871,266
Danfoss: paid through a US bank's UAE branch 2013–2017 Settlement OFAC 2022-12-30 $4,379,810
Commerzbank: a manual payment queue for Iranian counterparties 2002–2015 Settlement OFAC 2015-03-12 $258,660,796
Wells Fargo: software built to host what the bank wouldn't process 2007–2015 Settlement OFAC 2023-03-30 $30,000,000
Clearstream: one layer deeper in the custody chain 2007–2014 Settlement OFAC 2014-01-23 $151,902,000
BNP Paribas: the $963m correspondent banking settlement 2005–2014 Settlement OFAC 2014-06-30 $963,619,900
Fokker Services: 1,153 shipments of aircraft parts to Iran and Sudan 2005–2014 Settlement OFAC 2014-06-05 $50,922,208
Nasdaq: an Iranian bank on the member list nobody read sanctions into 2008–2014 Settlement OFAC 2023-12-08 $4,040,923
JPMorgan Chase: unscreened airline settlements 2008–2014 Settlement OFAC 2018-10-05 $5,263,171
UBAF: Syrian transfers booked inside, mirrored in dollars 2011–2013 Settlement OFAC 2021-01-04 $8,572,500
CSE TransTel: a promise to its bank, broken in two months 2010–2013 Settlement OFAC 2017-07-27 $12,027,066
UniCredit: a written guide to payments the US would not see 2007–2012 Settlement OFAC 2019-04-15 $611,023,421
Standard Chartered 2012: Sudan largest, all self-disclosed 2001–2012 Settlement OFAC 2012-12-10 $132,000,000
JPMorgan Chase: Cuba wires after an internal alert 2005–2011 Settlement OFAC 2011-08-25 $88,300,000
HSBC: Burma and Sudan, not just Iran 2004–2010 Settlement OFAC 2012-12-11 $375,000,000
Balli Aviation: three airliners for Mahan Air 2010 Settlement OFAC 2010-02-05 $15,000,000
Bank of Moscow: Bank Melli Iran as 'BMI CJSC' 2008–2009 Settlement OFAC 2014-01-27 $9,492,525
Crédit Agricole: Sudan through the Swiss subsidiary 2003–2008 Settlement OFAC 2015-10-20 $329,593,585
ING: 20,452 Cuba transactions, run from the branches 2002–2007 Settlement OFAC 2012-06-12 $619,000,000
Maersk Line, Limited: 4,714 shipments booked by the group 2003–2007 Settlement OFAC 2010-07-28 $3,088,400
BTMU: written instructions to strip payment messages 2006–2007 Settlement OFAC 2012-12-12 $8,571,634
Credit Suisse: standard procedures for cover payments 2002–2006 Settlement OFAC 2009-12-16 $536,000,000
Barclays: memos warned of a 'work around' 1987–2006 Settlement OFAC 2010-08-18 $176,000,000
Lloyds TSB: a policy of deleting sanctioned names 2003–2006 Settlement OFAC 2009-12-22 $217,000,000

How these were chosen

Every technique on this site has at least one case here, and that is enforced at build time rather than aspired to. The constraint on inclusion is documentary: a case appears only where a public enforcement document — a penalty notice, a designation press release, a charging document or a verdict — says what the conduct actually was. Each page is written from that document and links to it.

The consequence is that the mix is uneven, deliberately. Correspondent banking has ten cases because that is where enforcement has concentrated for fifteen years. Several techniques have exactly one, because one is what the public record supports. Where a case is unresolved it is marked as charges rather than findings, and the presumption of innocence is stated on the page.