National Commercial Bank — $653,347 OFAC penalty
OFAC published a $653,347 civil penalty against National Commercial Bank on 12/28/2020. It is the #122 largest action in OFAC’s 1,052-entry enforcement chart and #8 of the 15 actions published that year.
The record
| Entity, as published by OFAC | National Commercial Bank |
|---|---|
| Penalty / settlement amount | $653,347 |
| Date published by OFAC | 12/28/2020 |
| Aggregate penalties, settlements or findings | 1 |
| Rank among all published OFAC actions | #122 of 1,052 |
| Rank within 2020 | #8 of 15 |
| Share of 2020 penalty total | 2.8% |
| Apparent violations cited | 13 |
| Statutory maximum penalty | $12,111,632 |
| Base penalty | $1,814,854 |
| Voluntarily self-disclosed | Yes |
| OFAC egregiousness determination | Non-egregious |
| Sanctions programs named in the release | Syria, Sudan |
Settlement against statutory maximum
OFAC put the statutory maximum civil monetary penalty for this case at $12,111,632. The settled amount of $653,347 is 5.4% 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: 20201228_NCB.pdf. This page adds no facts beyond that document and OFAC’s published penalty chart.
Comparable 2020 actions
- Essentra FZE Company Limited — $665,112
- Deutsche Bank Trust Company Americas — $583,100
- Whitford Worldwide Company, LLC — $824,314
- Keysight Technologies Inc. — $473,157
- Comtech Telecommunications Corp. — $894,111
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