3M Company — $9,618,477 OFAC penalty
OFAC published a $9,618,477 civil penalty against 3M Company on 09/21/2023. It is the #33 largest action in OFAC’s 1,052-entry enforcement chart and #4 of the 16 actions published that year.
What OFAC said
Paul, Minnesota, has agreed to pay $9,618,477 to settle its potential civil liability for 54 apparent violations of OFAC sanctions on Iran.
Quoted verbatim from OFAC’s enforcement release — read the original.
The record
| Entity, as published by OFAC | 3M Company |
|---|---|
| Penalty / settlement amount | $9,618,477 |
| Date published by OFAC | 09/21/2023 (OFAC entry a) |
| Aggregate penalties, settlements or findings | 1 |
| Rank among all published OFAC actions | #33 of 1,052 |
| Rank within 2023 | #4 of 16 |
| Share of 2023 penalty total | 0.6% |
| Apparent violations cited | 54 |
| Statutory maximum penalty | $27,481,363 |
| Base penalty | $13,740,682 |
| Voluntarily self-disclosed | Yes |
| OFAC egregiousness determination | Egregious |
| Sanctions programs named in the release | Iran |
Settlement against statutory maximum
OFAC put the statutory maximum civil monetary penalty for this case at $27,481,363. The settled amount of $9,618,477 is 35.0% of that maximum, which OFAC's Enforcement Guidelines tie to factors including voluntary self-disclosure and whether the conduct was egregious.
Primary source
OFAC enforcement release: 20230921_3M.pdf. This page adds no facts beyond that document and OFAC’s published penalty chart.
Comparable 2023 actions
- Poloniex, LLC — $7,591,630
- Nasdaq, Inc. — $4,040,923
- Murad, LLC, and an Individual — $3,509,286
- Swedbank AS (Latvia) — $3,430,900
- Microsoft Corporation — $2,980,265.86
Screen against the live SDN list before you transact
Every action on this page began with a payment or transfer that was not screened. SanctionsAI is a free OFAC screening API for names and crypto wallets — read the API docs or check a wallet in the browser.