Who was sanctioned, and for what?

Mainly between February and November 2022, the London branch processed 970 payments totalling around 19.7 million GBP that breached Russia and anti-corruption sanctions. The causes were overloaded alert handling after the wave of designations, delayed escalation and human error; the bank voluntarily disclosed most of the breaches and received a 20% reduction from HM Treasury's Office of Financial Sanctions Implementation (OFSI).

Authority / court

HM Treasury, Office of Financial Sanctions Implementation (OFSI)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Russia (Sanctions) (EU Exit) Regulations 2019; Global Anti-Corruption Sanctions Regulations 2021; s. 146 Policing and Crime Act 2017

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Employees

10,000 or more

Mitigating circumstances

Predominantly voluntary disclosure and cooperation (20% reduction); exceptional burden caused by the 2022 sanctions packages taken into account

Published

2 Sep 2026

Original amount 4,732,830.58 GBP, converted at the ECB reference rate of 11 Aug 2026.

Checked against the official source on 25 Sep 2026 · Direct link

On 30 April 2026 OFSI imposed a monetary penalty of GBP 165,000 on the London branch of Deutsche Bank AG by way of settlement. According to OFSI's findings, in June and July 2022 the branch processed two payments totalling GBP 635,618.75 for a customer to a Russian app developer owned by a designated entity. According to OFSI, its screening provider's list did not contain ownership information on the designated entity, so the beneficiary was not identified. The bank had voluntarily disclosed the payments on 20 September 2022. After a notice of intent of 12 September 2025, which OFSI upheld on 2 December 2025, the bank requested a ministerial review on 23 January 2026; the proceedings ended in settlement. The publication does not state the amount originally proposed. Source: Office of Financial Sanctions Implementation (OFSI), HM Treasury, "Imposition of Monetary Penalty – Deutsche Bank AG London Branch (“DBLB”)", 19 May 2026, https://www.gov.uk/government/publications/imposition-of-monetary-penalty-deutsche-bank-ag-london-branch-dblb. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).

Authority / court

HM Treasury, Office of Financial Sanctions Implementation (OFSI)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Russia (Sanctions) (EU Exit) Regulations 2019, reg. 12; Geldbuße nach s. 146 Policing and Crime Act 2017

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Published

19 May 2026

Original amount 165,000 GBP, converted at the ECB reference rate of 30 Apr 2026.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

Online broker TradeStation Securities, Inc. of Florida is paying USD 1,110,661 under a settlement with OFAC for 481 apparent violations of multiple sanctions programmes. According to OFAC's findings, following several failures in compliance controls, customers in Iran, Syria and Crimea were able to execute 481 securities trades worth a total of USD 4,442,645 via the mobile app between June 2021 and June 2022. OFAC treated the apparent violations as non-egregious and voluntarily self-disclosed and credited significant remedial measures; the base penalty was USD 2,221,322. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "TradeStation Securities, Inc. Settles with OFAC for $1,110,661 Related to Apparent Violations of Multiple Sanctions Regulations", 17 March 2026, https://ofac.treasury.gov/media/935351/download?inline; summarised in our own words.

Authority / court

U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Iranian Transactions and Sanctions Regulations, 31 C.F.R. § 560.204; Syrian Sanctions Regulations, 31 C.F.R. § 542.207; Ukraine-/Russia-Related Sanctions Regulations, 31 C.F.R. § 589.207 (481 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Published

17 Mar 2026

Original amount 1,110,661 USD, converted at the ECB reference rate of 17 Mar 2026.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

In 2017/2018, the Chicago fund manager specialising in data centres took in capital from a Russian oligarch via nested structures and continued to manage this investment for four years after his designation in April 2018. The US Treasury's Office of Foreign Assets Control (OFAC) assessed the case as non-egregious and not voluntarily self-disclosed.

Authority / court

U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Ukraine-/Russia-Related Sanctions Regulations (31 C.F.R. part 589); IEEPA

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Mitigating circumstances

No prior violations in five years; cooperation improved significantly only after initially insufficient engagement (including waiver of attorney-client privilege), hence only limited credit

Published

2 Dec 2025

Original amount 11,485,352 USD, converted at the ECB reference rate of 2 Dec 2025.

Checked against the official source on 27 Sep 2026 · Version 2 · Direct link

US fintech Exodus Movement, Inc. is paying USD 3,103,360 under a settlement with OFAC for 254 apparent violations of the Iran sanctions. According to OFAC's findings, Exodus provided customer support to users in Iran and in some cases helped them access third-party crypto exchanges through its own wallet software. According to OFAC, on twelve occasions staff, despite being aware of the sanctions, advised users to hide their location via VPN in order to circumvent those exchanges' controls; OFAC treated these instances as egregious. The apparent violations were not voluntarily disclosed; the base penalty was USD 4,774,400. Extensive remediation and cooperation were taken into account. Exodus satisfies USD 630,000 of the settlement amount by investing in additional sanctions controls; USD 2,473,360 is payable to the Treasury. OFAC signed the settlement agreement on 19 November 2025 and published it on 16 December 2025. According to the settlement agreement, the settlement does not constitute an admission by Exodus of the apparent violations. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "Exodus Movement, Inc. Settles with OFAC for $3,103,360 for Apparent Violations of Iran-related Sanctions Regulations", 16 December 2025, https://ofac.treasury.gov/media/934831/download?inline; summarised in our own words.

Authority / court

U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Iranian Transactions and Sanctions Regulations, 31 C.F.R. § 560.204 (254 mutmaßliche Verstöße), in 12 Fällen zusätzlich § 560.203 (Umgehung); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Published

16 Dec 2025

Original amount 3,103,360 USD, converted at the ECB reference rate of 19 Nov 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

On 10 November 2025 OFSI imposed a monetary penalty of GBP 160,000 on Bank of Scotland PLC; without the 50 per cent discount for voluntary disclosure it would have been GBP 320,000, according to OFSI. According to OFSI's findings, between 8 and 24 February 2023 the bank processed 24 payments totalling GBP 77,383.39 through the account of a person designated under Russia sanctions, including credits of GBP 76,000. According to OFSI, screening failed to pick up a variant of the name, and a human error occurred during a PEP review on 20 February 2023. The notice of intent of 28 August 2025 had proposed GBP 175,000. The bank did not request a ministerial review. Source: Office of Financial Sanctions Implementation (OFSI), HM Treasury, "Imposition of monetary penalty: Bank of Scotland PLC", 26 January 2026, https://www.gov.uk/government/publications/imposition-of-monetary-penalty-bank-of-scotland-plc. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).

Authority / court

HM Treasury, Office of Financial Sanctions Implementation (OFSI)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Russia (Sanctions) (EU Exit) Regulations 2019, reg. 11, 12; Geldbuße nach s. 146 Policing and Crime Act 2017

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Published

26 Jan 2026

Original amount 160,000 GBP, converted at the ECB reference rate of 10 Nov 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

Crypto exchange ShapeShift AG, incorporated in Switzerland and operated from Denver, Colorado, is paying USD 750,000 under a settlement with OFAC for apparent violations of multiple sanctions programmes. According to OFAC's findings, between December 2016 and October 2018 ShapeShift exchanged digital assets worth USD 12,570,956 with users in Cuba, Iran, Sudan and Syria in 17,183 instances, although IP addresses revealed their location. The company introduced a sanctions compliance programme only after receiving an OFAC subpoena. OFAC treated the apparent violations as non-egregious and not voluntarily self-disclosed; the base penalty was USD 39,515,000. The low settlement amount reflects the fact that ShapeShift has ceased operations and has limited assets. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "ShapeShift AG Settles with OFAC for $750,000 Related to Apparent Violations of Multiple Sanctions Programs", 22 September 2025, https://ofac.treasury.gov/media/934641/download?inline; summarised in our own words.

Authority / court

U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Cuban Assets Control Regulations, 31 C.F.R. § 515.201(b) (39); Iranian Transactions and Sanctions Regulations, 31 C.F.R. § 560.204 (16.839); Sudanese Sanctions Regulations, 31 C.F.R. § 538.205 (33); Syrian Sanctions Regulations, 31 C.F.R. § 542.207 (272); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Published

22 Sep 2025

Original amount 750,000 USD, converted at the ECB reference rate of 22 Sep 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

On 8 September 2025 OFSI published a report on sanctions breaches by Vanquis Bank Limited but did not impose a monetary penalty. According to OFSI's findings, the account of a person designated under counter-terrorism sanctions remained fully usable for eight days after the designation; during that time GBP 200 was withdrawn in cash and a purchase of GBP 8.99 was made. OFSI had given the bank advance notice the day before the designation. According to OFSI, the staff responsible had been redeployed to remediation work, so the internal one-day deadline for the freeze was missed. The bank reported the breach itself, but only 13 days after the designation. Type of measure: Breach published by OFSI instead of a monetary penalty (disclosure under s. 149(3) PACA 2017). The publication does not mention any pending review. Source: Office of Financial Sanctions Implementation (OFSI), HM Treasury, "Disclosure notice: 08 September 2025", 8 September 2025, https://www.gov.uk/government/publications/disclosure-notice-08-september-2025. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).

Authority / court

HM Treasury, Office of Financial Sanctions Implementation (OFSI)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

regulations 11 and 12 of the Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019; Veröffentlichung nach section 149(3) Policing and Crime Act 2017

Action

Other

Status of proceedings

unknown

Sector

Financial services and insurance

Published

8 Sep 2025

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

Online broker Interactive Brokers LLC of Greenwich, Connecticut, is paying USD 11,832,136 under a settlement with OFAC for apparent violations of multiple sanctions programmes. According to OFAC's findings, between July 2016 and January 2024 the company provided brokerage and investment services to persons in Iran, Cuba, Syria and Crimea, processed trades in securities covered by the Chinese Military-Industrial Complex programme, carried out transactions involving blocked persons under several programmes and made prohibited new investment in Russia; 12,367 transactions were involved in total. OFAC treated the apparent violations as non-egregious and voluntarily self-disclosed and credited significant remediation and cooperation; the base penalty was USD 60,130,059. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "Interactive Brokers LLC Settles with OFAC for $11,832,136 Related to Apparent Violations of Multiple Sanctions Regulations", 15 July 2025, https://ofac.treasury.gov/media/934501/download?inline; summarised in our own words.

Authority / court

U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

E.O. 13685 § 1(a)(iii), E.O. 14024 §§ 1, 4(a), E.O. 14071 § 1(a)(i); 31 C.F.R. § 515.201 (Kuba), §§ 542.201, 542.207 (Syrien), § 560.204 (Iran), § 583.201 (Global Magnitsky), § 586.201 (Chinese Military-Industrial Complex), § 587.201 (Russian Harmful Foreign Activities), § 591.201 (Venezuela); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Published

15 Jul 2025

Original amount 11,832,136 USD, converted at the ECB reference rate of 15 Jul 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

OFAC has imposed the statutory maximum penalty of USD 215,988,868 on San Francisco venture capital firm GVA Capital Ltd. by way of a Penalty Notice. According to OFAC's findings, between April 2018 and May 2021 GVA Capital knowingly managed an investment for a sanctioned Russian oligarch despite knowing of his blocked status, working with a relative who acted as his proxy. The company also failed to comply fully with an OFAC subpoena for 28 months. OFAC treated the violations as egregious and not voluntarily self-disclosed. The Penalty Notice was preceded by Pre-Penalty Notices dated 13 September 2023 and 22 August 2024. The publication does not mention any pending review. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "OFAC Imposes $215,988,868 Penalty on GVA Capital Ltd. for Violating Ukraine/Russia-Related Sanctions and Reporting Obligations", 12 June 2025, https://ofac.treasury.gov/media/934366/download?inline; summarised in our own words.

Authority / court

U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Ukraine-/Russia-Related Sanctions Regulations, 31 C.F.R. §§ 589.201(a)(3), 589.201(b)(1), 589.213(a); Reporting, Procedures and Penalties Regulations, 31 C.F.R. § 501.602 (28 Verstöße, Subpoena); Penalty Notice nach 31 C.F.R. § 589.703 und den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A

Action

Fine

Status of proceedings

unknown

Sector

Financial services and insurance

Published

12 Jun 2025

Original amount 215,988,868 USD, converted at the ECB reference rate of 12 Jun 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

Gulating lagmannsrett (Gulating Court of Appeal) sentenced Rogaland Sparebank (formerly Sandnes Sparebank) to a corporate fine of NOK 1,200,000 because in April and May 2020 the bank failed to freeze an account opened in the name of a person on the UN Al-Qaida sanctions list and booked 13 payments totalling NOK 45,828 to it; the bank must also pay NOK 50,000 in legal costs. Hordaland tingrett (district court) had initially acquitted the bank; on 21 May 2025 the appeals committee of the Høyesterett (Supreme Court) refused leave for the bank's appeal.

Authority / court

Gulating lagmannsrett

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

§ 2 lov om bindende FN-vedtak i. V. m. § 3 forskrift om sanksjoner mot ISIL (Da'esh) og Al-Qaida; §§ 27 und 28 straffeloven

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Mitigating circumstances

The bank discovered the matter itself, took measures and reported it to Økokrim and later to Finanstilsynet and the Ministry of Foreign Affairs; it gained nothing from the breach.

Liability of senior managers

According to the court of appeal, it is the responsibility of management and the board to staff the bank so that sanctions obligations are complied with.

Original amount 1,200,000 NOK, converted at the ECB reference rate of 27 Feb 2025.

Checked against the official source on 28 Sep 2026 · Direct link

On 10 January 2025 OFSI imposed a monetary penalty of GBP 300,000 on the UK company Markom Management Limited, which in 2018 provided fiduciary, administration and bookkeeping services to companies. According to OFSI's findings, on 20 February 2018 the company instructed the return of an overpayment of around GBP 416,590 to a person designated under EU law, thereby making funds directly available to that person. OFSI attributed this to a lack of processes, poor knowledge of sanctions and a wish to make the payment quickly. The company reported the breach in October 2018; OFSI did not grant a disclosure discount. The notice of intent of 1 August 2024 had proposed GBP 400,000; after representations from the company OFSI reduced the amount. A ministerial review upheld the penalty on 4 June 2025. The publication does not mention any pending review. Source: Office of Financial Sanctions Implementation (OFSI), HM Treasury, "Imposition of monetary penalty: Markom Management Limited", 31 July 2025, https://www.gov.uk/government/publications/imposition-of-monetary-penalty-markom-management-limited. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).

Authority / court

HM Treasury, Office of Financial Sanctions Implementation (OFSI)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Ukraine (European Union Financial Sanctions) (No. 2) Regulations 2014 (Umsetzung der Verordnung (EU) Nr. 269/2014); Geldbuße nach s. 146 Policing and Crime Act 2017

Action

Fine

Status of proceedings

unknown

Sector

Financial services and insurance

Published

31 Jul 2025

Original amount 300,000 GBP, converted at the ECB reference rate of 10 Jan 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

The CSSF issued a reprimand to the Luxembourg branch because in 2022 it implemented financial sanctions under Regulation (EU) No 269/2014 late in respect of two accounts of a listed client and informed the Ministry of Finance late. Automatic fee and interest postings continued on the accounts; according to the CSSF, the listed person did not access any funds.

Authority / court

Commission de Surveillance du Secteur Financier (CSSF)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Art. 6(4) Loi du 19 décembre 2020 relative aux mesures restrictives en matière financière; Art. 8-4(1) und (2) Loi modifiée du 12 novembre 2004 (LBC/FT); verletzt Art. 2 und 7 VO (EU) Nr. 269/2014, Art. 6(1) Gesetz 2020, Règlement grand-ducal du 14 novembre 2022, Art. 33(2) Règlement CSSF 12-02

Action

Reprimand or warning

Status of proceedings

unknown

Sector

Financial services and insurance

Mitigating circumstances

The CSSF took into account the branch's remedial measures.

Published

12 Feb 2025

Checked against the official source on 2 Oct 2026 · Direct link

American Life Insurance Company (ALICO), a Delaware-based US insurer with global group and individual business, is paying USD 178,421 under a settlement with OFAC for apparent violations of the Iran sanctions. According to OFAC's findings, between February 2022 and August 2023 ALICO insured three policyholders in the United Arab Emirates that were owned or controlled by the Government of Iran and therefore blocked, including schools; in total 2,331 premiums and claims worth USD 446,077 were processed. Screening alerts were wrongly closed as false positives. OFAC treated the apparent violations as non-egregious and voluntarily self-disclosed; the base penalty was USD 223,038. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "American Life Insurance Company Settles with OFAC for $178,421 Related to Apparent Violations of Iranian Transactions and Sanctions Regulations", 14 November 2024, https://ofac.treasury.gov/media/933596/download?inline; summarised in our own words.

Authority / court

U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Iranian Transactions and Sanctions Regulations, 31 C.F.R. §§ 560.204 (Dienstleistungsexport), 560.211 (gesperrtes Vermögen); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Published

14 Nov 2024

Original amount 178,421 USD, converted at the ECB reference rate of 14 Nov 2024.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

A Massachusetts custody bank is paying USD 7,452,501 under a settlement with OFAC on behalf of itself and its software subsidiary for 38 apparent violations of the Ukraine-/Russia-related sanctions. According to OFAC's findings, between 2016 and 2020 the software subsidiary repeatedly redated or reissued invoices worth around USD 1.27 million to customers subject to Directive 1 under Executive Order 13662 and accepted payments after the permitted debt tenors had expired, which amounted to prohibited new debt. OFAC treated the apparent violations as egregious and not voluntarily self-disclosed and took cooperation and remediation into account; the base penalty equalled the statutory maximum of USD 13,550,002. OFAC signed the settlement agreement on 7 June 2024 and published it on 26 July 2024. Summarised in our own words.

Authority / court

U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Ukraine-/Russia-Related Sanctions Regulations, 31 C.F.R. § 589.202 i. V. m. Directive 1 zu E.O. 13662 (38 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Published

26 Jul 2024

Original amount 7,452,501 USD, converted at the ECB reference rate of 7 Jun 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 7 Jun 2026 · Direct link

A Swiss private banking group is paying USD 3,740,442 under a settlement with OFAC for apparent violations of multiple sanctions programmes; USD 1,000,000 of this is suspended pending completion of certain compliance commitments. According to OFAC's findings, between 2014 and 2018 entities of the group caused US securities firms to process 727 securities transactions worth USD 29,939,701 for customers in Cuba and 141 transactions worth USD 468,615 for a person blocked under the Kingpin Act; in 2023 five dividend payments to a person blocked under the Russia sanctions followed. In total 873 transactions worth USD 30,409,488 were involved. OFAC treated the apparent violations as voluntarily self-disclosed and non-egregious; the base penalty was USD 10,686,977. Summarised in our own words.

Authority / court

U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Cuban Assets Control Regulations, 31 C.F.R. § 515.201; Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. § 598.202; Russian Harmful Foreign Activities Sanctions Regulations, 31 C.F.R. § 587.201; Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Published

14 Mar 2024

Original amount 3,740,442 USD, converted at the ECB reference rate of 14 Mar 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 14 Mar 2026 · Direct link

An insurer based in New York State is paying USD 466,200 under a settlement with OFAC for 39 apparent violations of the Ukraine-/Russia-related sanctions. According to OFAC's findings, between May 2018 and July 2020 the company processed transactions totalling USD 315,891 relating to four insurance policies of a Panamanian company owned by a person on the SDN List and therefore itself blocked. According to OFAC, it had been known within the company since 2010 that the policies covered that person's property. OFAC treated the apparent violations as non-egregious and not voluntarily self-disclosed; the base penalty was USD 666,000. Summarised in our own words.

Authority / court

U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Ukraine-/Russia-Related Sanctions Regulations, 31 C.F.R. § 589.201(a)(4)(iii) (39 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Published

21 Dec 2023

Original amount 466,200 USD, converted at the ECB reference rate of 21 Dec 2023.

Checked against the official source on 28 Sep 2026 · Version 5 · Company name anonymised since 21 Dec 2025 · Direct link

A San Francisco crypto trading platform agreed to a settlement with OFAC of USD 1,207,830. According to OFAC's findings, between April 2020 and May 2022 the company processed 989 transactions worth around USD 1.25 million for users ordinarily resident in Crimea. Most of the 89 accounts concerned gave Russia as the country of residence but listed addresses in Crimea; screening did not pick up the address field. OFAC treated the apparent violations as non-egregious and not voluntarily self-disclosed; the base penalty was USD 3,097,000. In view of the company's financial circumstances, USD 300,000 of the settlement amount is suspended as long as it meets its compliance commitments; a further USD 300,000 is treated as satisfied if the company invests that amount in additional sanctions controls. Summarised in our own words.

Authority / court

U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Ukraine-/Russia-Related Sanctions Regulations, 31 C.F.R. § 589.207 (989 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Published

13 Dec 2023

Original amount 1,207,830 USD, converted at the ECB reference rate of 13 Dec 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 13 Dec 2025 · Direct link

A New York exchange operator is paying USD 4,040,923 under a settlement with OFAC for the conduct of its former Armenian subsidiary, which operated the Armenian Stock Exchange. According to OFAC's findings, between December 2012 and September 2014 the subsidiary processed 151 transactions with a face value of around USD 227.9 million on its trading platforms with the Armenian subsidiary of a designated Iranian state-owned bank, thereby knowingly exporting services to Iran and the Government of Iran. OFAC treated the apparent violations as non-egregious and voluntarily self-disclosed. Summarised in our own words.

Authority / court

U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Iranian Transactions and Sanctions Regulations, 31 C.F.R. § 560.215 (151 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Published

8 Dec 2023

Original amount 4,040,923 USD, converted at the ECB reference rate of 8 Dec 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 8 Dec 2025 · Direct link

A Cayman Islands-registered crypto exchange is paying USD 968,618,825 under a settlement with OFAC for 1,667,153 apparent violations of multiple sanctions programmes. According to OFAC's findings, from August 2017 to October 2022 its trading platform matched virtual currency trades worth around USD 706 million between US users and users in sanctioned jurisdictions or blocked persons. According to OFAC, senior management knew of and permitted the presence of US users and users from sanctioned jurisdictions on the platform, misled third parties about its controls and encouraged users to circumvent its own controls. OFAC treated the case as egregious and not voluntarily self-disclosed; the base penalty equalled the statutory maximum. The company reached parallel resolutions with the DOJ, FinCEN and the CFTC; USD 898,618,825 of the OFAC amount is deemed satisfied by the payment to the DOJ. The company must also retain an independent compliance monitor for five years. Summarised in our own words.

Authority / court

U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Iranian Transactions and Sanctions Regulations, 31 C.F.R. § 560.204; Syrian Sanctions Regulations, 31 C.F.R. § 542.207; North Korea Sanctions Regulations, 31 C.F.R. §§ 510.206, 510.212, E.O. 13722; Ukraine-/Russia-Related Sanctions Regulations, 31 C.F.R. §§ 589.207, 589.213, E.O. 13685; Cuban Assets Control Regulations, 31 C.F.R. § 515.201; E.O. 14065; IEEPA § 206(a); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Published

21 Nov 2023

Original amount 968,618,825 USD, converted at the ECB reference rate of 21 Nov 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 21 Nov 2025 · Direct link