Union de Banques Arabes et Françaises — $8,572,500 OFAC penalty
OFAC published a $8,572,500 civil penalty against Union de Banques Arabes et Françaises on 01/04/2021. It is the #36 largest action in OFAC’s 1,052-entry enforcement chart and #1 of the 18 actions published that year.
The record
| Entity, as published by OFAC | Union de Banques Arabes et Françaises |
|---|---|
| Penalty / settlement amount | $8,572,500 |
| Date published by OFAC | 01/04/2021 |
| Aggregate penalties, settlements or findings | 1 |
| Rank among all published OFAC actions | #36 of 1,052 |
| Rank within 2021 | #1 of 18 |
| Share of 2021 penalty total | 41.0% |
| Apparent violations cited | 127 |
| Statutory maximum penalty | $4,158,679,887.04 |
| Base penalty | $15,875,000 |
| Voluntarily self-disclosed | Yes |
| OFAC egregiousness determination | Non-egregious |
| Conduct period cited | August 2011 - April 2013 |
| Sanctions programs named in the release | Syria, Weapons Proliferation |
Settlement against statutory maximum
OFAC put the statutory maximum civil monetary penalty for this case at $4,158,679,887.04. The settled amount of $8,572,500 is 0.2% 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: 01042021_UBAF.pdf. This page adds no facts beyond that document and OFAC’s published penalty chart.
Comparable 2021 actions
- Bank of China (UK) Limited — $2,329,991
- SAP SE — $2,132,174
- Cameron International Corporation — $1,423,766
- Payoneer Inc. — $1,385,901.40
- PT Bukit Muria Jaya — $1,016,000
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