The second half of 2023 saw eight enforcement actions from the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”).  These actions reflect a range of penalties, industries, sanctions programs, conduct, and lessons learned.  Below are some highlights from OFAC’s enforcement releases and settlement agreements.

Penalties

OFAC imposed a total of $984,851,289.90 in penalties during the second half of the year, ranging from $31,867.90 against New York-based Emigrant Bank (“Emigrant”) to $968,618,825 against Binance Holdings, Ltd. (“Binance”), a Cayman Islands virtual currency exchange with affiliates around the world.  In one settlement, for $1,207,830 with CoinList Markets LLC (“CLM”), a California-based virtual currency exchange, OFAC suspended $300,000 of the settlement amount considering “the individual facts of this case, including CLM’s financial circumstances.”  This amount is suspended pending satisfactory completion of CLM’s compliance commitments as agreed to in the settlement.  Additionally, as partial satisfaction of the settlement amount, CLM agreed to invest $300,000 in additional sanctions compliance controls.