Nasdaq, Inc. — $4,040,923 OFAC penalty
OFAC published a $4,040,923 civil penalty against Nasdaq, Inc. on 12/08/2023. It is the #58 largest action in OFAC’s 1,052-entry enforcement chart and #6 of the 16 actions published that year.
The record
| Entity, as published by OFAC | Nasdaq, Inc. |
|---|---|
| Penalty / settlement amount | $4,040,923 |
| Date published by OFAC | 12/08/2023 |
| Aggregate penalties, settlements or findings | 1 |
| Rank among all published OFAC actions | #58 of 1,052 |
| Rank within 2023 | #6 of 16 |
| Share of 2023 penalty total | 0.3% |
| Statutory maximum penalty | $458,503,738 |
| Voluntarily self-disclosed | Yes |
| OFAC egregiousness determination | Non-egregious |
| Sanctions programs named in the release | Iran, Weapons Proliferation |
Settlement against statutory maximum
OFAC put the statutory maximum civil monetary penalty for this case at $458,503,738. The settled amount of $4,040,923 is 0.9% 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: 20231208_nasdaq.pdf. This page adds no facts beyond that document and OFAC’s published penalty chart.
Comparable 2023 actions
- Murad, LLC, and an Individual — $3,509,286
- Swedbank AS (Latvia) — $3,430,900
- Microsoft Corporation — $2,980,265.86
- CoinList Markets LLC — $1,207,830
- Construction Specialties Inc. — $660,954
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