CA Indosuez Switzerland S.A. — $720,258 OFAC penalty
OFAC published a $720,258 civil penalty against CA Indosuez Switzerland S.A. on 09/26/2022. It is the #118 largest action in OFAC’s 1,052-entry enforcement chart and #5 of the 14 actions published that year.
The record
| Entity, as published by OFAC | CA Indosuez Switzerland S.A. |
|---|---|
| Penalty / settlement amount | $720,258 |
| Date published by OFAC | 09/26/2022 (OFAC entry a) |
| Aggregate penalties, settlements or findings | 1 |
| Rank among all published OFAC actions | #118 of 1,052 |
| Rank within 2022 | #5 of 14 |
| Share of 2022 penalty total | 1.7% |
| Statutory maximum penalty | $64,062,841 |
| Base penalty | $1,108,090 |
| Voluntarily self-disclosed | Yes |
| OFAC egregiousness determination | Non-egregious |
| Conduct period cited | April 2013 - April 2016 |
| Sanctions programs named in the release | Iran, Cuba, Syria, Ukraine/Crimea, Sudan |
Settlement against statutory maximum
OFAC put the statutory maximum civil monetary penalty for this case at $64,062,841. The settled amount of $720,258 is 1.1% 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: 20220926_CAIS.pdf. This page adds no facts beyond that document and OFAC’s published penalty chart.
Comparable 2022 actions
- American Express National Bank — $430,500
- CFM Indosuez Wealth — $401,039
- Payward, Inc. (“Kraken”) — $362,158.70
- Banco Popular de Puerto Rico — $255,937.86
- Newmont Corporation — $141,442
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