AppliChem — $5,512,564 OFAC penalty
OFAC published a $5,512,564 civil penalty against AppliChem on 02/14/2019. It is the #50 largest action in OFAC’s 1,052-entry enforcement chart and #3 of the 22 actions published that year.
The record
| Entity, as published by OFAC | AppliChem |
|---|---|
| Penalty / settlement amount | $5,512,564 |
| Date published by OFAC | 02/14/2019 |
| Aggregate penalties, settlements or findings | 1 |
| Rank among all published OFAC actions | #50 of 1,052 |
| Rank within 2019 | #3 of 22 |
| Share of 2019 penalty total | 0.4% |
| Statutory maximum penalty | $20,045,688 |
| Base penalty | $10,022,844 |
| Voluntarily self-disclosed | Yes |
| OFAC egregiousness determination | Egregious |
| Conduct period cited | May 2012 - February 2016 |
| Sanctions programs named in the release | Cuba |
Settlement against statutory maximum
OFAC put the statutory maximum civil monetary penalty for this case at $20,045,688. The settled amount of $5,512,564 is 27.5% 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: 20190214_applichem.pdf. This page adds no facts beyond that document and OFAC’s published penalty chart.
Comparable 2019 actions
- British Arab Commercial Bank plc — $4,000,000
- The General Electric Company — $2,718,581
- Stanley Black and Decker — $1,869,144
- PACCAR Inc. — $1,709,325
- e.l.f. Cosmetics — $996,080
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