Sanctions settlements as a governance cost, part 1: the 14 penalties of 2026

The US Office of Foreign Assets Control (OFAC) has published nine civil penalties and settlements in 2026, worth $295,983,600, according to its enforcement page, the latest being Bank of America's $11.7 million settlement on 13 October. The UK's Office of Financial Sanctions Implementation (OFSI) has published five monetary penalties this year totalling £6.45 million, its enforcement collection shows. This series treats those records as a measure of what weak sanctions controls cost a company and its board. Part 1 sets out the 2026 cases and what moved the amounts.

Date	Party	Authority	Amount	Assessment	Source
13 Oct	Bank of America, N.A.	OFAC	$11,662,930	Non-egregious, largely not self-disclosed; no reduction from base	notice
9 Oct	Pegasus Worldwide Logistics	OFAC	$175,015	Non-egregious, not self-disclosed; base $205,900	notice
10 Sep	An individual (Iran)	OFAC	$1,427,230	Egregious, not self-disclosed; base $14,730,300	notice
11 Aug	Citibank N.A., London Branch	OFSI	£4,732,830.58	Most breaches disclosed; 20% discount	notice
12 Aug	Rice Lake Weighing Systems	OFAC	$60,764	Non-egregious, self-disclosed; equal to base	notice
1 Jun	FTI Consulting	OFAC	$1,050,000	Non-egregious, not self-disclosed; base $525,000, raised above it	notice
26 May	Sabre Global Technologies	OFSI	£1,000,920.59	Self-disclosed; settled	notice
18 May	Adani Enterprises	OFAC	$275,000,000	Egregious, not self-disclosed; base $384,208,088	notice
30 Apr	Deutsche Bank AG, London Branch	OFSI	£165,000	Self-disclosed; settled	notice
19 Mar	Apple Distribution International	OFSI	£390,000	Self-disclosed; settled	notice
17 Mar	TradeStation Securities	OFAC	$1,110,661	Non-egregious, self-disclosed; base $2,221,322	notice
25 Feb	An individual (Syria)	OFAC	$3,777,000	Egregious, not self-disclosed; base $7,554,000	notice
12 Feb	IMG Academy	OFAC	$1,720,000	Non-egregious, not self-disclosed; equal to base	notice
26 Jan*	Bank of Scotland	OFSI	£160,000	Self-disclosed; full 50% discount	notice

Dates are those of the OFAC release or of OFSI's imposition or settlement. *OFSI imposed the Bank of Scotland penalty on 10 November 2025 and published it on 26 January 2026.

One case dominates

Adani Enterprises, headquartered in India, accounts for 92.9 per cent of OFAC's 2026 total; the other eight cases add up to $20,983,600. OFAC found 32 apparent violations, involving about $192.1 million of dollar payments for Iranian-origin liquefied petroleum gas bought from a Dubai supplier, and judged the case egregious and not voluntarily disclosed, so the base penalty was the statutory maximum of $384,208,088, the release says. The settlement of $275 million, 71.6 per cent of that base, reflects remedial measures and cooperation. OFAC said the company relied on the 2020 sanctions compliance programme of Adani Ports and Special Economic Zone, which barred Iranian cargo from the ports it controlled but did not cover the other risks in the trade, and that "It does not appear that AEL took sufficient action in response to any of these red flags while the Apparent Violations were ongoing." It listed recklessness among the aggravating factors.

What moves the number

Under OFAC's guidelines the two judgements that set the base are whether a case is egregious and whether it was voluntarily self-disclosed. TradeStation, which disclosed its 481 apparent violations, had a base of half the transaction value, $2,221,322, and settled for half of that, with OFAC citing "significant remedial measures" (release). Bank of America received "no reduction to the base penalty, including no mitigation for remedial measures or cooperation" (release). FTI Consulting paid twice its $525,000 base; OFAC said the amount was "aggravated above the base penalty" in view of "the importance of anticipated impact of promoting future compliance by similarly situated persons" (release).

OFSI uses discounts. Bank of Scotland received the full 50 per cent discount for voluntary disclosure (notice). Citibank's London branch received 20 per cent for disclosure and cooperation; it disclosed most of the breaches, which involved 970 payments worth £19.7 million, while others reached OFSI by other means. OFSI linked many of the breaches to strain on alert handling after the 2022 Russia designations (notice). OFSI introduced a framework for settling penalty cases on 9 February 2026, its notice on Sabre Global Technologies records (notice).

The same payments, two penalties

Two of the UK cases concern payments of the same size. Apple Distribution International instructed two payments in June and July 2022 totalling £635,618 and was penalised £390,000 (notice). Deutsche Bank's London branch was penalised £165,000 for processing two payments in the same months totalling £635,618.75, on behalf of a customer, to a company wholly owned by a person designated under the UK's Russia sanctions (notice). Both disclosed. On these records, the customer that instructs a payment and the bank that processes it can each be liable for the same transfer.

Part 2 will read the compliance commitments that OFAC attaches to settlements, and what they ask of boards and audit committees.