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Companies fined for sanctions violations: cases and amounts

Published enforcement cases with the authority, the date, the amount in the original currency, what happened in one sentence and a link to the official source.

In short

Published cases on this page: 58. Authorities: 9. Years: 2022 to 2026.

The cases are penalties, settlements and court judgments for breaches of sanctions and of related export controls, as published by the authorities.

In the United States (OFAC, BIS) and in the United Kingdom (OFSI, since 15 June 2022) civil liability is strict: a company can be fined even if it did not know that the counterparty was sanctioned.

Amounts are shown in the currency of the decision and are never converted.

Cases by country

Cases by sector

Cases

Cases shown: 58 of 58

SectorWhat happened
Extreme Networks, Inc.Civil enforcement action (penalty or settlement)United StatesElectronics and dual-use goodsOFAC (US Treasury) + DOJ (US Department of Justice) OFAC: $1,529,685
DOJ: $975,721.84
Through its Russian subsidiary Extreme sold networking equipment to a company majority-owned by a sanctioned Russian air-defence maker. Official source verified on November 13, 2026
Bank of America, N.A.Civil enforcement action (penalty or settlement)United StatesBanks and financial intermediariesOFAC (US Treasury) $11,662,930 The bank processed payments involving blocked banks, mishandled screening alerts for exact matches and updated its watchlists late. Official source verified on November 13, 2026
Pegasus Worldwide LogisticsCivil enforcement action (penalty or settlement)United StatesLogistics and shippingOFAC (US Treasury) $175,015 The company arranged a shipment of equipment from a sanctioned Chinese supplier without noticing, because of gaps in its checks. Official source verified on November 13, 2026
Illumina Cambridge LimitedCompound settlement (not a conviction)United KingdomElectronics and dual-use goodsHMRC £7,438,840.13 The company was involved in moving sanctioned goods between two overseas group companies, with the goods going to Russia. Official source verified on November 13, 2026
Citibank, N.A., London BranchMonetary penaltyUnited KingdomBanks and financial intermediariesOFSI (HM Treasury) £4,732,830.58 The bank processed 970 payments worth £19.7m that dealt with frozen funds or made funds available to designated persons, including companies owned by Sovcomflot and designated Russian banks. Official source verified on November 13, 2026
Airbus Operations LimitedCompound settlement for export control breaches (not sanctions)United KingdomAerospace and defenceHMRC £6,409,388 The company repeatedly failed to keep the required records of transfers of controlled technology under its export licences. Official source verified on November 13, 2026
Petrofac Facilities Management LimitedCompound settlement (not a conviction)United KingdomMachinery and industrial equipmentHMRC £569,157.07 While leaving Russia, the company supplied sanctioned industrial goods to persons connected with Russia and gave technical assistance for them. Official source verified on November 13, 2026
Sabre Global Technologies LimitedMonetary penaltyUnited KingdomTechnology and softwareOFSI (HM Treasury) £1,000,920.59 Sabre kept receiving payments from, and giving booking-system access to, the designated Ural Airlines after its designation. Official source verified on November 13, 2026
FTI Consulting, Inc.Civil enforcement action (penalty or settlement)United StatesProfessional services (law, accounting, consulting)OFAC (US Treasury) $1,050,000 The firm extended prohibited credit to the sanctioned Russian bank VTB by issuing invoices that were paid late or not at all. Official source verified on November 13, 2026
Deutsche Bank AG London BranchMonetary penaltyUnited KingdomBanks and financial intermediariesOFSI (HM Treasury) £165,000 On a client's instruction the branch made two payments of £635,618.75 to Okko LLC, a company owned by a designated entity; its screening data did not show the ownership. Official source verified on November 13, 2026
Adani Enterprises LimitedCivil enforcement action (penalty or settlement)IndiaMetals, chemicals and commoditiesOFAC (US Treasury) $275,000,000 The company bought LPG from a Dubai trader that claimed Omani and Iraqi origin despite red flags that it came from Iran. Official source verified on November 13, 2026
LAFARGE SACriminal court judgmentFirst-instance judgment.FranceManufacturing for exportTribunal judiciaire de Paris €1,125,000 (criminal fine)
€4,570,000 (customs fine, jointly and severally)
Through its Syrian subsidiary the group paid about €5.6m to ISIS and other armed groups via intermediaries and suppliers they controlled, breaching EU sanctions. Official source verified on November 13, 2026
Apple Distribution International LimitedMonetary penaltyIrelandTechnology and softwareOFSI (HM Treasury) £390,000 The Irish company ordered two payments of £635,618.75 to a Russian app developer owned by a UK-designated entity. Official source verified on November 13, 2026
Applied Materials Inc. and Applied Materials Korea, Ltd.Civil enforcement action (penalty or settlement)United StatesElectronics and dual-use goodsBIS (US Department of Commerce) about $252,000,000 The company shipped ion implanters without a licence to a Chinese company on the Entity List, routing them through its Korean subsidiary. Official source verified on November 13, 2026
Commerciale I.C. - Pacific Inc.Anti money laundering penalty (not a sanctions violation)Appeal pending when verified.CanadaCrypto and paymentsFINTRAC CA$224,235 The money transfer business was fined, among other things, for not reporting 110 transactions to or from Iran as the ministerial directive requires. Official source verified on November 13, 2026
Bank of Scotland PLCMonetary penaltyUnited KingdomBanks and financial intermediariesOFSI (HM Treasury) £160,000 The bank processed 24 payments of £77,383 to or from the account of a designated person, missed because of a spelling variation of the name. Official source verified on November 13, 2026
MP Technology Services Ltd. (MoonPay)Anti money laundering penalty (not a sanctions violation)Appeal pending when verified.CanadaCrypto and paymentsFINTRAC CA$536,853.35 The company was fined for AML failures, including not reporting attempted transactions from wallets exposed to sanctioned entities. Official source verified on November 13, 2026
Exodus Movement, Inc.Civil enforcement action (penalty or settlement)United StatesCrypto and paymentsOFAC (US Treasury) $3,103,360 The company gave support to users in Iran and sometimes told them to use VPNs to hide their location. Official source verified on November 13, 2026
IPI Partners, LLCCivil enforcement action (penalty or settlement)United StatesBanks and financial intermediariesOFAC (US Treasury) $11,485,352 The firm took investments from a sanctioned Russian oligarch through legal structures and kept them for four years after his designation. Official source verified on November 13, 2026
Xeltox Enterprises Ltd. (Cryptomus)Anti money laundering penalty (not a sanctions violation)CanadaCrypto and paymentsFINTRAC CA$176,960,190 The crypto platform was fined for anti-money-laundering failures, including not reporting 7,557 Iran-linked transactions and flows linked to sanctions evasion. Official source verified on November 13, 2026
Luminultra Technologies, Inc.Administrative settlementThe penalty concerns the US subsidiary of the Canadian group.CanadaMetals, chemicals and commoditiesBIS (US Department of Commerce) $685,051 The company shipped testing devices and kits to a distributor in Tehran, naming a Dubai freight forwarder to hide the destination. Official source verified on November 13, 2026
Colorcon LimitedMonetary penaltyUnited KingdomManufacturing for exportOFSI (HM Treasury) £152,750 Its Moscow office paid staff and suppliers through accounts at designated Russian banks (Alfa, Promsvyazbank, Sberbank, VTB): 79 payments worth £128,278 were breaches. Official source verified on November 13, 2026
ShapeShift AGCivil enforcement action (penalty or settlement)SwitzerlandCrypto and paymentsOFAC (US Treasury) $750,000 The exchange carried out crypto trades with users in Cuba, Iran, Sudan and Syria. Official source verified on November 13, 2026
Vanquis Bank LimitedBreach published, no fineUnited KingdomBanks and financial intermediariesOFSI (HM Treasury) Breach published, no fine A designated person kept full access to their account for eight days after designation and withdrew cash. Official source verified on November 13, 2026
Fracht FWO Inc.Civil enforcement action (penalty or settlement)United StatesLogistics and shippingOFAC (US Treasury) $1,610,775 The freight forwarder hired a blocked Venezuelan state airline to carry cargo, and the airline used an aircraft blocked as operated by Iran's Mahan Air. Official source verified on November 13, 2026
Markom Management LimitedMonetary penaltyUnited KingdomProfessional services (law, accounting, consulting)OFSI (HM Treasury) £300,000 The firm instructed a bank to transfer £416,591 from a client's account to a designated person, knowing who the recipient was. Official source verified on November 13, 2026
Cadence Design Systems Inc.Guilty plea (DOJ) and BIS penaltyUnited StatesElectronics and dual-use goodsDOJ (US Department of Justice) + BIS (US Department of Commerce) more than $140,000,000 Cadence and its Chinese subsidiary exported controlled chip-design tools without licences to a Chinese military university on the Entity List, through an alias. Official source verified on November 13, 2026
Interactive Brokers LLCCivil enforcement action (penalty or settlement)United StatesBanks and financial intermediariesOFAC (US Treasury) $11,832,136 The broker served persons in Iran, Cuba, Syria and Crimea and carried out trades involving blocked persons and prohibited securities. Official source verified on November 13, 2026
Company not namedCompound settlement (not a conviction)United KingdomExporter (sector not published)HMRC £1,160,725.67 A UK company made goods available to Russia in breach of the Russia sanctions regulations. Official source verified on November 13, 2026
Harman International Industries, Inc.Civil enforcement action (penalty or settlement)United StatesElectronics and dual-use goodsOFAC (US Treasury) $1,454,145 Employees of a Harman subsidiary let its UAE distributor divert Harman products to Iran. Official source verified on November 13, 2026
Unicat Catalyst Technologies, LLCCivil enforcement action (penalty or settlement)Amount of the OFAC decision only.United StatesMetals, chemicals and commoditiesOFAC (US Treasury) $3,882,797 The former CEO and staff supplied catalysts and services to customers in Iran and sold goods to a blocked Venezuelan company. Official source verified on November 13, 2026
GVA Capital Ltd.Monetary penaltyUnited StatesBanks and financial intermediariesOFAC (US Treasury) $215,988,868 The firm kept managing an investment for a sanctioned Russian oligarch after his designation, working through his nephew as a front. Official source verified on November 13, 2026
Svarog Shipping & Trading Company LimitedPenalty for not answering an information requestUnited KingdomLogistics and shippingOFSI (HM Treasury) £5,000 The company failed to answer an OFSI information request on time during an inquiry into its dealings with a Sovcomflot subsidiary. Official source verified on November 13, 2026
Herbert Smith Freehills CIS LLP (Moscow)Monetary penaltyUnited KingdomProfessional services (law, accounting, consulting)OFSI (HM Treasury) £465,000 While closing its Moscow office, the firm made six payments worth £3.9m (rent, fees, overdraft) to designated Russian banks. Official source verified on November 13, 2026
Haas Automation, Inc.Civil enforcement action (penalty or settlement)United StatesMachinery and industrial equipmentOFAC (US Treasury) + BIS (US Department of Commerce) OFAC: $1,044,781
BIS: $1,500,000
Through its distributor network Haas supplied a CNC machine, spare parts and activation codes for machines owned by blocked Russian entities. Official source verified on November 13, 2026
SkyGeek Logistics, Inc.Civil enforcement action (penalty or settlement)United StatesAerospace and defenceOFAC (US Treasury) $22,172 The company sent four shipments of aviation products to two UAE companies sanctioned for supporting Russia's aerospace sector. Official source verified on November 13, 2026
C.H. Robinson International Inc.Civil enforcement action (penalty or settlement)United StatesLogistics and shippingOFAC (US Treasury) $257,690 Five foreign subsidiaries arranged 82 shipments involving Iran or Iranian or Cuban goods, or dealt with an Iranian airline. Official source verified on November 13, 2026
Aiotec GmbHCivil enforcement action (penalty or settlement)GermanyMachinery and industrial equipmentOFAC (US Treasury) $14,550,000 The company arranged for an Australian polypropylene plant brokered by a US firm to be resold to Iran, with payments through US banks. Official source verified on November 13, 2026
American Life Insurance Company (MetLife)Civil enforcement action (penalty or settlement)United StatesInsuranceOFAC (US Treasury) $178,421 The insurer issued group policies to UAE schools and entities owned or controlled by the Government of Iran. Official source verified on November 13, 2026
Swiss holding company not named, and its managerCriminal court judgmentNot final at the time of the bulletin of the German Federal Ministry for Economic Affairs (BMWK) of 14 March 2025.Germany / SwitzerlandMachinery and industrial equipmentOLG Stuttgart about €3,000,000 (confiscation (holding company))
€2,100,000 (manager, not named, 7 years in prison)
The manager shipped six dual-use machine tools to a Russian sniper-rifle maker through companies in Switzerland and Lithuania. Official source verified on November 13, 2026
Integral Concierge Services LimitedMonetary penaltyUnited KingdomProperty and concierge servicesOFSI (HM Treasury) £15,000 The company kept managing a UK property for a designated client and handled 26 payments worth £15,487, including rent. Official source verified on November 13, 2026
Amsterdam company not namedOut-of-court settlement with the prosecutor (transactie)NetherlandsBanks and financial intermediariesOpenbaar Ministerie €195,000
€20,000 (director)
The company paid about €18m of dividends to a Russian shareholder behind which stood a listed person, and repaid money to an EU-listed Russian company. Official source verified on November 13, 2026
State Street Bank and Trust CompanyCivil enforcement action (penalty or settlement)United StatesBanks and financial intermediariesOFAC (US Treasury) $7,452,501 Its subsidiary Charles River redated invoices for Russian customers under sectoral sanctions and accepted their payments. Official source verified on November 13, 2026
Mondo TV S.p.A.Civil enforcement action (penalty or settlement)ItalyMediaOFAC (US Treasury) $538,000 The company paid about $538,000 to a North Korean state animation studio for outsourced work, through third-party companies. Official source verified on November 13, 2026
SCG Plastics Co., Ltd.Civil enforcement action (penalty or settlement)ThailandMetals, chemicals and commoditiesOFAC (US Treasury) $20,000,000 The company routed $291m of dollar payments through US banks for sales of Iranian-origin resin made by a joint venture in Iran. Official source verified on November 13, 2026
EFG International AGCivil enforcement action (penalty or settlement)SwitzerlandBanks and financial intermediariesOFAC (US Treasury) $3,740,442 The bank had US firms process securities trades for clients under Cuba, narcotics and Russia sanctions, including dividends to a blocked Russian. Official source verified on November 13, 2026
Privilege Underwriters Reciprocal Exchange (PURE)Civil enforcement action (penalty or settlement)United StatesInsuranceOFAC (US Treasury) $466,200 The insurer handled four policies involving a company owned by sanctioned Viktor Vekselberg. Official source verified on November 13, 2026
Binance Holdings, Ltd.Civil enforcement action (penalty or settlement)Cayman IslandsCrypto and paymentsOFAC (US Treasury) $968,618,825 For more than five years the exchange matched trades between US users and users in sanctioned countries or blocked persons. Official source verified on November 13, 2026
3M CompanyCivil enforcement action (penalty or settlement)United StatesManufacturing for exportOFAC (US Treasury) $9,618,477 3M's Swiss subsidiary sold reflective sheeting, through a German reseller, to an entity controlled by Iran's police forces. Official source verified on November 13, 2026
Wise Payments LimitedBreach published, no fineUnited KingdomCrypto and paymentsOFSI (HM Treasury) Breach published, no fine Wise allowed a £250 withdrawal from the business account of a company owned by a person designated the day before. Official source verified on November 13, 2026
Swedbank Latvia AS (Swedbank AB)Civil enforcement action (penalty or settlement)Sweden (group) / LatviaBanks and financial intermediariesOFAC (US Treasury) $3,430,900 A shipping client used the bank's e-banking from Crimea to send payments to persons in Crimea through US correspondent banks. Official source verified on November 13, 2026
British American Tobacco p.l.c.Civil enforcement action (penalty or settlement)United KingdomManufacturing for exportOFAC (US Treasury) $508,612,492 BAT moved about $250m from a North Korean joint venture through North Korean banks, and its Singapore subsidiary was paid for tobacco sold to the North Korean embassy. Official source verified on November 13, 2026
Seagate Technology LLCCivil enforcement action (penalty or settlement)United StatesElectronics and dual-use goodsBIS (US Department of Commerce) $300,000,000 Seagate supplied hard disk drives to Huawei, which is on the Entity List, in breach of the foreign direct product rule. Official source verified on November 13, 2026
Microsoft Corporation (also for Microsoft Ireland Operations Ltd.)Civil enforcement action (penalty or settlement)IrelandTechnology and softwareOFAC (US Treasury) + BIS (US Department of Commerce) OFAC: $2,980,265.86
BIS: $624,013
Microsoft Ireland billed resellers for licences that ended up with sanctioned persons and users in Russia, Crimea, Cuba, Iran and Syria. Official source verified on November 13, 2026
Danfoss A/SCivil enforcement action (penalty or settlement)DenmarkManufacturing for exportOFAC (US Treasury) $4,379,810 Its UAE subsidiary had customers in Iran, Syria and Sudan pay into a US bank's UAE branch and paid entities in Iran and Syria from it. Official source verified on November 13, 2026
Payward, Inc. (Kraken)Civil enforcement action (penalty or settlement)United StatesCrypto and paymentsOFAC (US Treasury) $362,158.70 The exchange served users who appeared to be in Iran because it did not block their IP addresses in time. Official source verified on November 13, 2026
CA Indosuez (Switzerland) S.A. (Crédit Agricole)Civil enforcement action (penalty or settlement)France (group) / SwitzerlandBanks and financial intermediariesOFAC (US Treasury) $720,258 The bank ran dollar accounts for 17 clients living in sanctioned countries, although its KYC files showed those addresses. Official source verified on November 13, 2026
Toll Holdings LimitedCivil enforcement action (penalty or settlement)AustraliaLogistics and shippingOFAC (US Treasury) $6,131,855 The logistics group made or received payments through the US system for shipments involving North Korea, Iran, Syria or sanctioned parties. Official source verified on November 13, 2026

Select a column heading to sort the table. Amounts are shown in the currency of the decision and are never converted.

Totals by year and by authority

Sums of the amounts imposed on companies in this list, by currency, never converted. Not included: breaches published without a fine, anti money laundering penalties, confiscations and amounts imposed on individuals. A total marked about or more than includes an amount that the source gives as approximate or as a minimum.

By year

YearCasesTotal
202615about $542,393,351.84; £20,866,136.37; €5,695,000
202516more than $393,337,265; £2,083,475.67
202410$46,739,226; €195,000; £15,000
20237$1,794,351,172.86
20224$11,594,081.70

By authority

AuthorityCasesTotal
OFAC (US Treasury)32$2,092,630,311.56
OFSI (HM Treasury)10£7,386,501.17
BIS (US Department of Commerce)5about $554,809,064
HMRC4£15,578,110.87
DOJ (US Department of Justice)1$975,721.84
DOJ (US Department of Justice) + BIS (US Department of Commerce)1more than $140,000,000
Openbaar Ministerie1€195,000
Tribunal judiciaire de Paris1€5,695,000

Maximum penalties set by law

Maximums in the law, as verified on the official texts linked:

  • United Kingdom, OFSI (financial sanctions): civil penalty up to the greater of £1,000,000 or 50% of the value of the breach; criminal offences up to 7 years in prison. Civil liability is strict since 15 June 2022. (Official source 1) (Official source 2)
  • United Kingdom, OTSI (trade sanctions): civil penalty up to the greater of £1,000,000 or 50% of the value since 10 October 2024, with strict civil liability; under customs law (CEMA section 68) up to 14 years in prison since 22 February 2024 (previously 7 or 10 years). (Official source 1) (Official source 2)
  • United States, OFAC (IEEPA): civil penalty up to the greater of $377,700 per violation or twice the value of the transaction; criminal penalty up to $1,000,000 and 20 years in prison. Civil liability is strict. (Official source 1) (Official source 2) (Official source 3)
  • United States, BIS (Export Control Reform Act): civil penalty up to the greater of $374,474 per violation or twice the value of the transaction; criminal penalty up to $1,000,000 and 20 years in prison. Civil liability is strict. (Official source 1) (Official source 2)
  • European Union, Directive (EU) 2024/1226: each Member State must provide, for companies, maximum fines of no less than 5% of worldwide turnover or €40 million (1% or €8 million for some reporting obligations), and for individuals maximum prison terms of at least 5 years for the main offences above €100,000 and for military or dual-use goods. The offences require intent (serious negligence for military and dual-use goods). Transposition deadline: 20 May 2025. (Official source)
  • Germany, Foreign Trade and Payments Act (AWG): fines on companies up to €40 million (§19); prison from 3 months to 5 years, up to 10 years in serious cases (§18). Directive transposed by the law of 5 February 2026. (Official source 1) (Official source 2)
  • Netherlands, Economic Offences Act (WED, article 6): up to 6 years in prison and a fine of the fifth category (or of the next higher category). For the transposition of the directive only a ministerial communication was found. (Official source)
  • Switzerland (not in the EU), Embargo Act (EmbG, article 9): up to 1 year in prison, 5 years in serious cases; negligence up to CHF 100,000. Verified only in part, on an unofficial text. (Official source)
  • France: former article 459 of the Customs Code, up to 5 years in prison, confiscation and a fine of one to two times the sum involved; recodified from 1 May 2026 as articles L. 542-1 and following. The directive has not been transposed in substance (bill no. 2544 pending). (Official source)
  • Ireland: a typical statutory instrument provides, on indictment, up to €500,000 or 3 years in prison. The directive has not been transposed: reasoned opinion of the European Commission of 6 October 2026 (secondary source). (Official source)
  • Sweden, Act (2025:327) on international sanctions, in force since 10 June 2025 and transposing the directive: up to 3 years in prison, serious offences 2 to 6 years. (Official source)
  • Canada, Special Economic Measures Act (section 8): no administrative penalties; on summary conviction a fine up to CAD 25,000 and/or 1 year in prison, on indictment up to 5 years. A wilful violation is required. (Official source)
  • Canada, Export and Import Permits Act: on summary conviction up to CAD 250,000 and/or 12 months; on indictment a fine at the discretion of the court and up to 10 years in prison; directors can also be liable. (Official source)
  • Italy: companies (Legislative Decree 231/2001, article 25-octies.2) from 1% to 5% of worldwide turnover, or from €3 million to €40 million; individuals (article 275-bis of the Criminal Code) 2 to 6 years in prison and from €25,000 to €250,000. Directive transposed by Legislative Decree 211/2025, in force since 24 January 2026. (Official source)

Frequently asked questions

How much can a company be fined for sanctions violations?

It depends on the country. United States: up to the greater of $377,700 per violation or twice the value of the transaction (OFAC), and up to $374,474 or twice the value for export controls (BIS). United Kingdom: up to the greater of £1,000,000 or 50% of the value of the breach (OFSI). European Union: each Member State must provide maximum fines for companies of no less than 5% of worldwide turnover or €40 million. The largest amounts in this list are: Binance Holdings, Ltd. (OFAC (US Treasury), November 21, 2023): $968,618,825; British American Tobacco p.l.c. (OFAC (US Treasury), April 25, 2023): $508,612,492; Seagate Technology LLC (BIS (US Department of Commerce), April 19, 2023): $300,000,000; Illumina Cambridge Limited (HMRC, Compound settlement (not a conviction), September 8, 2026): £7,438,840.13; Airbus Operations Limited (HMRC, Compound settlement for export control breaches (not sanctions), July 30, 2026): £6,409,388; Citibank, N.A., London Branch (OFSI (HM Treasury), September 2, 2026): £4,732,830.58; LAFARGE SA (Tribunal judiciaire de Paris, Criminal court judgment, April 13, 2026): €5,695,000; Amsterdam company not named (Openbaar Ministerie, Out-of-court settlement with the prosecutor (transactie), September 23, 2024): €195,000.

Who fines companies for sanctions violations?

In the United States OFAC (US Treasury), BIS (US Department of Commerce) and the DOJ; in the United Kingdom OFSI (HM Treasury), HMRC and, for trade sanctions, OTSI; in EU countries prosecutors and criminal courts, for example the Paris Judicial Court, the Dutch Public Prosecution Service and the Higher Regional Court of Stuttgart. US and UK authorities also act against companies based in other countries: 15 cases in this list.

Can a company be fined without knowing that the counterparty was sanctioned?

In the United States and in the United Kingdom, yes, for civil penalties. OFAC states that a US person may be held civilly liable even without having knowledge or reason to know of the violation; BIS civil liability is also strict; since 15 June 2022 OFSI no longer has to prove that a person knew or had reasonable cause to suspect. In the EU the directive requires intent, and serious negligence is enough for military and dual-use goods. In Canada a wilful violation is required. Example from this list: Pegasus Worldwide Logistics (OFAC, 9 October 2026) arranged a shipment of equipment from a sanctioned Chinese supplier without noticing, because of gaps in its checks.

Can a breach be published without a fine?

Yes. OFSI can publish a breach without imposing a penalty: in this list Wise Payments Limited (31 August 2023) and Vanquis Bank Limited (8 September 2025).

Can a company be fined if the sanctioned party is only an owner behind the counterparty?

Yes. In the United Kingdom Deutsche Bank AG London Branch (£165,000) and Apple Distribution International Limited (£390,000) were fined for the same two payments to Okko LLC, a company owned by a designated entity and not itself named on a list. In the United States the OFAC 50% rule on ownership remains in force.

How is this list kept up to date?

Each case was checked on the official source of the authority, court or ministry, and the date of the last verification is shown on the page. The list is not exhaustive.

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List not exhaustive, based on public official sources. Date of the last verification: November 13, 2026.

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