European Sanctions Enforcement Outdoes OFAC

In 2024, probably for the first time ever, Europe (meaning the EU, UK, Switzerland and Norway), imposed and obtained a greater number of fines and convictions; a higher total value of fines; and also a higher single largest fine, for sanctions breaches than those imposed by the authorities in the United States.

A note compiled by Mark Handley of Duane Morris, London, tallies combined enforcement actions taken by OFAC and BIS, as well as criminal convictions secured by the DOJ, as compared to their European peers.

Handley reports- 

"The US obtained 52 successfully-concluded enforcement actions, while Europe secured 118.

"The US (OFAC and BIS combined) imposed fines equivalent to €56.8m, while Europe imposed a total of €88.5m.

"The single largest US fine was $20m in relation to Iran sanctions. The largest fine in Europe was the UK’s £29m imposed on Starling Bank."