Swedbank AS (Latvia) — $3,430,900 OFAC penalty
OFAC published a $3,430,900 civil penalty against Swedbank AS (Latvia) on 06/20/2023. It is the #64 largest action in OFAC’s 1,052-entry enforcement chart and #8 of the 16 actions published that year.
The record
| Entity, as published by OFAC | Swedbank AS (Latvia) |
|---|---|
| Penalty / settlement amount | $3,430,900 |
| Date published by OFAC | 06/20/2023 |
| Aggregate penalties, settlements or findings | 1 |
| Rank among all published OFAC actions | #64 of 1,052 |
| Rank within 2023 | #8 of 16 |
| Share of 2023 penalty total | 0.2% |
| Apparent violations cited | 386 |
| Statutory maximum penalty | $112,322,552 |
| Voluntarily self-disclosed | No |
| OFAC egregiousness determination | Non-egregious |
| Sanctions programs named in the release | Russia, Ukraine/Crimea |
Settlement against statutory maximum
OFAC put the statutory maximum civil monetary penalty for this case at $112,322,552. The settled amount of $3,430,900 is 3.1% 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: 20230620_swedbank_latvia.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
- Microsoft Corporation — $2,980,265.86
- Nasdaq, Inc. — $4,040,923
- CoinList Markets LLC — $1,207,830
- Construction Specialties Inc. — $660,954
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