UNICORN PRIVATE Sanctions fines for banks and financial intermediaries
In short
Published cases on this page: 13. Authorities: 3. Years: 2022 to 2026.
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.
Good to know
- This page also includes brokers, asset managers, private equity firms and a holding company.
Cases
Cases shown: 13 of 13
| Sector | What happened | |||||
|---|---|---|---|---|---|---|
| Bank of America, N.A.Civil enforcement action (penalty or settlement) | United States | Banks and financial intermediaries | OFAC (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 | |
| Citibank, N.A., London BranchMonetary penalty | United Kingdom | Banks and financial intermediaries | OFSI (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 | |
| Deutsche Bank AG London BranchMonetary penalty | United Kingdom | Banks and financial intermediaries | OFSI (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 | |
| Bank of Scotland PLCMonetary penalty | United Kingdom | Banks and financial intermediaries | OFSI (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 | |
| IPI Partners, LLCCivil enforcement action (penalty or settlement) | United States | Banks and financial intermediaries | OFAC (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 | |
| Vanquis Bank LimitedBreach published, no fine | United Kingdom | Banks and financial intermediaries | OFSI (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 | |
| Interactive Brokers LLCCivil enforcement action (penalty or settlement) | United States | Banks and financial intermediaries | OFAC (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 | |
| GVA Capital Ltd.Monetary penalty | United States | Banks and financial intermediaries | OFAC (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 | |
| Amsterdam company not namedOut-of-court settlement with the prosecutor (transactie) | Netherlands | Banks and financial intermediaries | Openbaar 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 States | Banks and financial intermediaries | OFAC (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 | |
| EFG International AGCivil enforcement action (penalty or settlement) | Switzerland | Banks and financial intermediaries | OFAC (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 | |
| Swedbank Latvia AS (Swedbank AB)Civil enforcement action (penalty or settlement) | Sweden (group) / Latvia | Banks and financial intermediaries | OFAC (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 | |
| CA Indosuez (Switzerland) S.A. (Crédit Agricole)Civil enforcement action (penalty or settlement) | France (group) / Switzerland | Banks and financial intermediaries | OFAC (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 |
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
| Year | Cases | Total |
|---|---|---|
| 2026 | 4 | $11,662,930; £5,057,830.58 |
| 2025 | 3 | $239,306,356 |
| 2024 | 3 | $11,192,943; €195,000 |
| 2023 | 1 | $3,430,900 |
| 2022 | 1 | $720,258 |
By authority
| Authority | Cases | Total |
|---|---|---|
| OFAC (US Treasury) | 8 | $266,313,387 |
| OFSI (HM Treasury) | 3 | £5,057,830.58 |
| Openbaar Ministerie | 1 | €195,000 |
Frequently asked questions
Have companies in this sector been fined for sanctions violations?
This page lists 13 published cases. The largest amounts are: GVA Capital Ltd. (OFAC (US Treasury), June 12, 2025): $215,988,868; Interactive Brokers LLC (OFAC (US Treasury), July 15, 2025): $11,832,136; Bank of America, N.A. (OFAC (US Treasury), October 13, 2026): $11,662,930; Citibank, N.A., London Branch (OFSI (HM Treasury), September 2, 2026): £4,732,830.58; Deutsche Bank AG London Branch (OFSI (HM Treasury), May 19, 2026): £165,000; Bank of Scotland PLC (OFSI (HM Treasury), January 26, 2026): £160,000; Amsterdam company not named (Openbaar Ministerie, Out-of-court settlement with the prosecutor (transactie), September 23, 2024): €195,000. This page also includes brokers, asset managers, private equity firms and a holding company.
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.
Unicorn Intelligence is your corporate compliance officer: it checks all your customers and suppliers every day against sanctions lists and the other official lists, with the source and date of every item.
Check all your customers and suppliers for free
Upload your list and see in a few minutes how many names have sanctions, lawsuits, insolvency or other risks. Monitoring shows which ones, every day.
List not exhaustive, based on public official sources. Date of the last verification: November 13, 2026.
Unicorn Intelligence is an information tool: decisions and legal obligations remain with your company.