UNICORN PRIVATE Sanctions fines in the United States: OFAC and BIS penalties
Decisions of OFAC (US Treasury), BIS (US Department of Commerce) and the DOJ against US companies and against companies based in other countries.
In short
Published cases on this page: 36. 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
- Several companies in this list are based outside the United States: in the cases of SCG Plastics, Toll Holdings and Danfoss the payments passed through the US financial system.
- The BIS Affiliates Rule (the 50% rule for export controls) is suspended until 10 January 2027. The OFAC 50% rule on ownership remains in force.
- https://www.federalregister.gov/documents/2026/11/09/2026-22793/extension-of-the-suspension-of-expansion-of-end-user-controls-for-affiliates-of-certain-listed
- https://www.federalregister.gov/documents/2025/11/12/2025-19846/one-year-suspension-of-expansion-of-end-user-controls-for-affiliates-of-certain-listed-entities
Cases
Cases shown: 36 of 36
| Sector | What happened | |||||
|---|---|---|---|---|---|---|
| Extreme Networks, Inc.Civil enforcement action (penalty or settlement) | United States | Electronics and dual-use goods | OFAC (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 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 | |
| Pegasus Worldwide LogisticsCivil enforcement action (penalty or settlement) | United States | Logistics and shipping | OFAC (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 | |
| FTI Consulting, Inc.Civil enforcement action (penalty or settlement) | United States | Professional 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 | |
| Adani Enterprises LimitedCivil enforcement action (penalty or settlement) | India | Metals, chemicals and commodities | OFAC (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 | |
| Applied Materials Inc. and Applied Materials Korea, Ltd.Civil enforcement action (penalty or settlement) | United States | Electronics and dual-use goods | BIS (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 | |
| Exodus Movement, Inc.Civil enforcement action (penalty or settlement) | United States | Crypto and payments | OFAC (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 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 | |
| Luminultra Technologies, Inc.Administrative settlementThe penalty concerns the US subsidiary of the Canadian group. | Canada | Metals, chemicals and commodities | BIS (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 | |
| ShapeShift AGCivil enforcement action (penalty or settlement) | Switzerland | Crypto and payments | OFAC (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 | |
| Fracht FWO Inc.Civil enforcement action (penalty or settlement) | United States | Logistics and shipping | OFAC (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 | |
| Cadence Design Systems Inc.Guilty plea (DOJ) and BIS penalty | United States | Electronics and dual-use goods | DOJ (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 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 | |
| Harman International Industries, Inc.Civil enforcement action (penalty or settlement) | United States | Electronics and dual-use goods | OFAC (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 States | Metals, chemicals and commodities | OFAC (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 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 | |
| Haas Automation, Inc.Civil enforcement action (penalty or settlement) | United States | Machinery and industrial equipment | OFAC (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 States | Aerospace and defence | OFAC (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 States | Logistics and shipping | OFAC (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) | Germany | Machinery and industrial equipment | OFAC (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 States | Insurance | OFAC (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 | |
| 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 | |
| Mondo TV S.p.A.Civil enforcement action (penalty or settlement) | Italy | Media | OFAC (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) | Thailand | Metals, chemicals and commodities | OFAC (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) | 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 | |
| Privilege Underwriters Reciprocal Exchange (PURE)Civil enforcement action (penalty or settlement) | United States | Insurance | OFAC (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 Islands | Crypto and payments | OFAC (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 States | Manufacturing for export | OFAC (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 | |
| 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 | |
| British American Tobacco p.l.c.Civil enforcement action (penalty or settlement) | United Kingdom | Manufacturing for export | OFAC (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 States | Electronics and dual-use goods | BIS (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) | Ireland | Technology and software | OFAC (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) | Denmark | Manufacturing for export | OFAC (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 States | Crypto and payments | OFAC (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) / 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 | |
| Toll Holdings LimitedCivil enforcement action (penalty or settlement) | Australia | Logistics and shipping | OFAC (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
| Year | Cases | Total |
|---|---|---|
| 2026 | 6 | about $542,393,351.84 |
| 2025 | 11 | more than $393,337,265 |
| 2024 | 8 | $46,739,226 |
| 2023 | 7 | $1,794,351,172.86 |
| 2022 | 4 | $11,594,081.70 |
By authority
| Authority | Cases | Total |
|---|---|---|
| OFAC (US Treasury) | 32 | $2,092,630,311.56 |
| BIS (US Department of Commerce) | 5 | about $554,809,064 |
| DOJ (US Department of Justice) | 1 | $975,721.84 |
| DOJ (US Department of Justice) + BIS (US Department of Commerce) | 1 | more than $140,000,000 |
Maximum penalties set by law
Maximums in the law, as verified on the official texts linked:
- 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)
Frequently asked questions
How much can OFAC and BIS fine a company?
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. 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.
Which companies have been fined in cases involving this country?
This page lists 36 published cases. The largest amounts 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. Several companies in this list are based outside the United States: in the cases of SCG Plastics, Toll Holdings and Danfoss the payments passed through the US financial system.
Can OFAC fine a company that did not know the counterparty was sanctioned?
Yes. OFAC states that a US person may be held civilly liable for sanctions violations even without having knowledge or reason to know of the violation. BIS civil liability under the Export Control Reform Act is also strict. Criminal penalties concern wilful violations.
Who enforces US sanctions and export controls?
OFAC (US Treasury) enforces economic sanctions, BIS (US Department of Commerce) enforces export controls such as the Entity List, and the DOJ prosecutes criminal cases.
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List not exhaustive, based on public official sources. Date of the last verification: November 13, 2026.
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