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 27, each sourced to the penalty notice or court record.

cases written up

27

ofac penalty records

283

total penalties since 2009

$7.9bn

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, 283 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. 283 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: $283m across 6 actions. Largest: Adani Enterprises Limited.
The same figures as a table
YearActions TotalLargest single action
2026 6 $283m 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

27 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
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
TGR Group: cash in one city, USDT in another 2023–2024 Designation
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
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
Nordgas: re-exporting US pressure switches to Iran 2010–2021 Settlement OFAC 2021-03-26 $950,000
Essentra FZE: cigarette filters to North Korea through front companies 2018–2020 Settlement OFAC 2020-07-16 $665,112
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
Epsilon Electronics: selling to a distributor that sold to Iran 2008–2018 Settlement OFAC 2018-09-13 $1,500,000
ZTE: front companies and an internal plan to keep supplying Iran 2010–2017 Criminal conviction OFAC 2017-03-07 $100,871,266
Commerzbank: a manual payment queue for Iranian counterparties 2002–2015 Settlement OFAC 2015-03-12 $258,660,796
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

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.