British American Tobacco p.l.c. — $508,612,492 OFAC penalty
OFAC published a $508,612,492 civil penalty against British American Tobacco p.l.c. on 04/25/2023. It is the #7 largest action in OFAC’s 1,052-entry enforcement chart and #2 of the 16 actions published that year.
The record
| Entity, as published by OFAC | British American Tobacco p.l.c. |
|---|---|
| Penalty / settlement amount | $508,612,492 |
| Date published by OFAC | 04/25/2023 |
| Aggregate penalties, settlements or findings | 1 |
| Rank among all published OFAC actions | #7 of 1,052 |
| Rank within 2023 | #2 of 16 |
| Share of 2023 penalty total | 33.0% |
| Statutory maximum penalty | $508,612,492 |
| Voluntarily self-disclosed | No |
| OFAC egregiousness determination | Egregious |
| Sanctions programs named in the release | North Korea, Weapons Proliferation |
Settlement against statutory maximum
OFAC put the statutory maximum civil monetary penalty for this case at $508,612,492. The settled amount of $508,612,492 is 100.0% 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: 20230425_bat.pdf. This page adds no facts beyond that document and OFAC’s published penalty chart.
Comparable 2023 actions
- Binance — $968,618,825
- Wells Fargo Bank, N.A. — $30,000,000
- 3M Company — $9,618,477
- Poloniex, LLC — $7,591,630
- Nasdaq, Inc. — $4,040,923
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