US report on sanctions penalties

January 01, 1970 by Mark Dunn

Posted on by  Michael O'Kane on

The US Government Accountability Office (GAO), an independent monitor of federal government spending, has published a report on the fines and penalties imposed on financial institutions for violations of US sanctions and other financial crime regulations.  The report states that, between January 2009 and December 2015, around $12bn of fines, penalties, and forfeitures were assessed by federal agencies, of which $6.8bn was for sanctions violations.  Federal agencies are said to have collected all but $100m of the $12bn due.

Of the $6.8bn, $301m in penalties was imposed by OFAC, in amounts ranging from $8,700 to $152m, and $5.7bn in criminal and civil forfeitures and fines was assessed by the Department of Justice and participating Treasury offices and law enforcement partners.  Most of the $5.7bn was assessed against BNP Paribas in 2014 for moving over $8.8bn through the US financial system on behalf of sanctioned entities (see previous blog).

This article first appeared on European Sanctions Law & Practice (, a blog by Maya Lester (+44 20 7379 3550,, a barrister at Brick Court Chambers, and Michael O'Kane (+44 (0) 20 7822 7777, head of Business Crime at Peters & Peters.