Berkshire Hathaway, Inc. — $4,144,651 OFAC penalty
OFAC published a $4,144,651 civil penalty against Berkshire Hathaway, Inc. on 10/20/2020. It is the #57 largest action in OFAC’s 1,052-entry enforcement chart and #3 of the 15 actions published that year.
The record
| Entity, as published by OFAC | Berkshire Hathaway, Inc. |
|---|---|
| Penalty / settlement amount | $4,144,651 |
| Date published by OFAC | 10/20/2020 |
| Aggregate penalties, settlements or findings | 1 |
| Rank among all published OFAC actions | #57 of 1,052 |
| Rank within 2020 | #3 of 15 |
| Share of 2020 penalty total | 17.6% |
| Statutory maximum penalty | $36,841,344 |
| Base penalty | $18,420,672 |
| Voluntarily self-disclosed | Yes |
| OFAC egregiousness determination | Egregious |
| Sanctions programs named in the release | Iran, Syria |
Settlement against statutory maximum
OFAC put the statutory maximum civil monetary penalty for this case at $36,841,344. The settled amount of $4,144,651 is 11.2% 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: 20201020_berkshire.pdf. This page adds no facts beyond that document and OFAC’s published penalty chart.
Comparable 2020 actions
- Generali Global Assistance, Inc. — $5,864,860
- Eagle Shipping International (USA) LLC — $1,125,000
- Comtech Telecommunications Corp. — $894,111
- Whitford Worldwide Company, LLC — $824,314
- Essentra FZE Company Limited — $665,112
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