Cost of Non-Compliance
The price of getting export controls wrong, in public dollars.
A live dataset of public enforcement actions across BIS, DDTC, OFAC and DOJ — drawn from official agency releases. Filter by agency, year, or conduct; click any row for the underlying source. This page rebuilds whenever the dataset moves.
Assessed in agency settlements
$9.7B
325 actions tracked
Mean penalty
$29.8M
per agency settlement
Largest action on record
$4.3B
Binance Holdings Ltd. · Nov 2023 (includes multi-agency consolidations)
Voluntary disclosure savings
~50%
OFAC base-penalty reduction (typical, public guidance)
Trend
Penalties by year, stacked by agency.
Bars show the sum of agency-specific settlements per calendar year. Multi-agency consolidations (e.g. the Binance $4.3B settlement) are annotated separately to avoid double-counting the BIS / OFAC / DOJ rows that already feed those totals.
- BIS
- DDTC
- OFAC
- DOJ
- Multi-agency
+ $5.4B in 4 multi-agency consolidations not stacked above (totals already reflected in the agency-specific rows).
Dataset: 325 sampled enforcement actions, 2005–2026. U.S. sanctions / export-control sample, OFAC-weighted; backfill across BIS administrative cases is in progress.
Settlements
Every action, on the record.
Use the toggle in each row to expand the conduct summary and the source document. Filters update the URL — share a view by copying the address bar.
329 actions matching
| Date | Respondent | Agency | Conduct | Penalty |
|---|---|---|---|---|
| General Electric Company | DDTC | Settled alleged AECA/ITAR violations involving unauthorized exports of technical data to the People's Republic of China, unauthorized exports of defense articles, violations of license terms and provisos, and failure to report material changes to its ITAR registration. Civil penalty of $36 million, with $18 million suspended for remedial compliance. | $36,000,000 | |
| Exodus Movement, Inc. | OFAC | Apparent ITSR violations: digital-asset wallet provider provided customer-support services to users in Iran, in some cases recommending VPNs to circumvent third-party exchange geoblocks. | $3,103,360 | |
| An Individual | OFAC | Apparent Ukraine-/Russia-Related Sanctions Regulations violations: a U.S. attorney continued serving as fiduciary of a family trust funded by a sanctioned Russian oligarch (SDN-1) after his 2018 designation. | $1,092,000 | |
| Gracetown, Inc. | OFAC | Egregious Ukraine-/Russia-Related Sanctions Regulations violations: New York property-management company continued receiving payments tied to Oleg Deripaska after his designation and failed to timely report blocked property. | $7,139,305 | |
| IPI Partners, LLC | OFAC | Apparent Ukraine-/Russia-Related Sanctions Regulations violations: Chicago private-equity fund manager maintained a $50M investment from Russian oligarch Suleiman Kerimov, routed through a BVI shell, for years after his April 2018 designation. | $11,485,352 | |
| An Individual | OFAC | Egregious Russian Harmful Foreign Activities Sanctions Regulations violations: U.S. person acting through Atlanta-based King Holdings LLC willfully renovated and sold blocked residential real property of a sanctioned Russian oligarch's family member, defying an OFAC cease-and-desist order. | $4,677,552 | |
| ShapeShift AG | OFAC | Apparent violations of the ITSR, CACR, Sudanese Sanctions, and Syrian Sanctions Regulations: digital-asset exchange processed 17,183 transactions with users in Iran, Cuba, Sudan, and Syria due to a lack of any sanctions-screening program. | $750,000 | |
| Fracht FWO Inc. | OFAC | Egregious apparent violations of Venezuela, Iran (Mahan Air), and counter-terrorism sanctions: Houston freight forwarder chartered a Mexico-to-Argentina cargo flight on a blocked CONVIASA-subsidiary aircraft previously identified as Iranian Mahan Air property. | $1,610,775 | |
| Interactive Brokers LLC | OFAC | Apparent violations of the ITSR, CACR, Syrian Sanctions, Crimea, and Russia-related sanctions programs: Connecticut-based broker-dealer exported brokerage services to ~200 accountholders in Iran, Cuba, Syria, and Crimea and processed transfers to blocked Russian banks. | $11,832,136 | |
| Harman International Industries, Inc. | OFAC | Egregious apparent ITSR violations: U.K.-based British Sales Team of U.S. subsidiary Harman Professional knowingly enabled a UAE distributor to divert audio-electronics products to Iran, using code phrases like "the northern region." | $1,454,145 | |
| Key Holding, LLC | OFAC | Apparent CACR violations: Delaware logistics company's newly acquired Colombian subsidiary (Key Logistics Colombia) brokered 36 freight shipments of foodstuffs and oil-well machinery from Colombia to Cuba with no sanctions-compliance program in place. | $608,825 | |
| Unicat Catalyst Technologies, LLC | OFAC | Egregious apparent ITSR and Venezuela-sanctions violations: Texas catalyst supplier's former CEO and employees willfully sold petrochemical catalyst products and on-site technical services to end-users in Iran and a blocked Venezuelan entity, using code letters to conceal Iran shipments. | $3,882,797 | |
| GVA Capital LLC | OFAC | Apparent Russia-related sanctions violations: managed an investment for an SDN-listed Russian oligarch's affiliate after the designation, in apparent violation of the Russian Harmful Foreign Activities Sanctions Regulations. | $215,988,868 | |
| Haas Automation, Inc. | OFAC | Apparent Ukraine-/Russia-Related Sanctions Regulations violations: California CNC machine-tool maker indirectly supplied a machine, spare parts, and unlock codes to six blocked Russian entities via Russian distributor Abamet between 2019 and 2022. | $1,044,781 | |
| Family International Realty LLC and an Individual | OFAC | Egregious Ukraine-/Russia-Related Sanctions Regulations violations: Miami real-estate company and its owner orchestrated a scheme to transfer nominal ownership of three Florida luxury condos owned by sanctioned Russian oligarchs Abramov and Perevalov to non-sanctioned family members and shell companies. | $1,076,923 | |
| SkyGeek Logistics, Inc. | OFAC | Apparent RuHSR violations: New York aviation-parts supplier shipped goods and attempted refunds to two UAE-based aircraft-parts entities (Flavic FZE and Mirage) after they were added to the SDN List for supporting Russia's aerospace and technology sectors. | $22,172 | |
| An Individual | OFAC | Apparent Global Magnitsky Sanctions Regulations violations: U.S. corporate officer of an equine-industry company executed six payments totaling $45,179 on behalf of the company's CEO after that CEO was designated under E.O. 13818 for human-rights abuse and corruption. | $45,179 | |
| Córdoba Music Group LLC | OFAC | Apparent ITSR violations: California musical-instrument manufacturer shipped instruments and accessories valued at $118,831 to a Dubai-based intermediary on nine occasions with knowledge they were ultimately destined for Iran. | $41,591 | |
| C.H. Robinson International Inc. | OFAC | Apparent ITSR and CACR violations: Minnesota-based logistics company's five non-U.S. subsidiaries (in China, Spain, Canada, Australia, Peru) provided freight-brokerage services for 82 shipments to or from Iran and involving Iranian- or Cuban-origin goods, including dealings with Iran's Mahan Air. | $257,690 | |
| GlobalFoundries U.S. Inc. | BIS | Settled administrative charges for shipping wafers to a non-affiliated SMIC subsidiary on the BIS Entity List without the required licenses. | $500,000 | |
| Aiotec GmbH | OFAC | Apparent ITSR violations: brokered the sale of a U.S.-origin polypropylene plant to an Iranian end-user with knowledge of the destination. | $14,550,000 | |
| An Individual | OFAC | Egregious apparent ITSR violations: U.S. person executed a multi-year scheme to purchase, renovate, and operate a 19-suite hotel on Iran's Caspian Sea coast, using Canadian and Iranian money services businesses and informal value transfer systems to evade U.S. sanctions. | $1,104,408 | |
| American Life Insurance Company | OFAC | Apparent ITSR violations: MetLife's Delaware subsidiary ALICO issued group medical and life policies and processed 2,331 premium/claim transactions for UAE-based schools and an entity owned or controlled by the Government of Iran after a compliance escalation was overridden. | $178,421 | |
| Vietnam Beverage Company Limited | OFAC | Apparent North Korea Sanctions Regulations violations: Vietnamese holding company's alcoholic-beverage subsidiaries executed 26 contracts to ship beer and spirits to two North Korean entities, causing U.S. banks to process 43 wire transfers totaling ~$1.14 million. | $860,000 | |
| Precision Castparts Corp. | DDTC | Settled alleged AECA/ITAR violations involving unauthorized exports of technical data to foreign-person employees from Bhutan, Burundi, El Salvador, Honduras, Mexico, and Peru relating to wax pattern and core dies and wax patterns used to produce gas-turbine casting blades. | $3,000,000 | |
| State Street Bank and Trust Company | OFAC | Apparent violations of the Ukraine-/Russia-Related Sanctions Regulations involving custody-account distributions to a blocked Russian counterparty. | $7,452,501 | |
| Mondo Verde Inc. | BIS | Settled administrative charges for unlicensed exports of EAR-controlled chemical-detection equipment to Russia and Belarus following the 2022 sanctions tightening. | $250,000 | |
| RTX Corporation | DDTC | Settled alleged AECA/ITAR violations involving unauthorized exports of defense articles (including classified articles) caused by jurisdiction and classification failures, employee hand-carries to ITAR § 126.1 proscribed destinations, and violations of license terms and provisos. Civil penalty of $200 million, with $100 million suspended for remedial compliance. | $200,000,000 | |
| Toll Holdings Limited | OFAC | Apparent violations of multiple sanctions programs (Iran, North Korea, Syria) via originating or receiving sea-freight shipments to or from sanctioned jurisdictions on behalf of customers. | $6,131,855 | |
| Indium Corporation of America | BIS | Settled charges for unlicensed exports of EAR-controlled solder products to listed Russian end-users after the post-Ukraine sanctions tightening. | $836,500 | |
| State Street Bank and Trust Company and its subsidiary, Charles River Systems, Inc. | OFAC | Egregious apparent Ukraine-/Russia-Related Sanctions Regulations violations: Charles River Systems (acquired by State Street in 2018) accepted invoice payments outside Directive 1 debt-tenor limits from SSI-listed Sberbank and VTB Bank subsidiaries on 38 occasions between 2016 and 2020. | $7,452,501 | |
| Mondo TV, S.p.a. | OFAC | Apparent North Korea Sanctions Regulations violations: Rome-based animation company remitted approximately $537,939 via 18 wire transfers processed through U.S. banks to North Korea's state-owned SEK Studio for outsourced animation work. | $538,000 | |
| SCB Inc. | OFAC | Apparent violations of the Cuban Assets Control Regulations involving processing of dental supply orders for Cuban clinics through U.S. intermediaries. | $21,908 | |
| AerCap Ireland Limited | OFAC | Self-disclosed apparent violations involving aircraft leases to Russian airlines that were not unwound before the post-invasion sanctions deadlines. | $3,360,000 | |
| 3M Company | OFAC | Apparent ITSR violations: a German subsidiary, through a third-party distributor, sold reflective license-plate sheeting ultimately destined for the Iranian national police. | $9,618,477 | |
| SCG Plastics Co., Ltd. | OFAC | Egregious apparent ITSR violations: Thai trading company caused U.S. banks to process $291 million in wire transfers for sales of Iranian-origin high-density polyethylene produced by an Iran joint venture (Mehr) tied to the National Petrochemical Company of Iran, using deceptive shipping documents listing "Middle East" or UAE as origin. | $20,000,000 | |
| EFG International AG | OFAC | Apparent violations of the CACR, Foreign Narcotics Kingpin Sanctions Regulations, and RuHSR: Swiss private banking group caused U.S. securities firms to process 873 transactions totaling ~$30.4 million on behalf of Cuban-resident clients, a Kingpin-designated client, and a Russia-related SDN. | $3,740,442 | |
| The Boeing Company | DDTC | Settled alleged AECA/ITAR violations involving unauthorized exports and retransfers of technical data to foreign-person employees and contractors, unauthorized exports to the People's Republic of China, and violations of license terms, conditions, and provisos. Civil penalty of $51 million, with $24 million suspended for remedial compliance. | $51,000,000 | |
| SAP SEcombined | Multi-agency | Multi-agency resolution (DOJ, BIS, OFAC) for export-control and ITSR violations involving software exports to Iran via foreign subsidiaries and third-party resellers. | $222,000,000 | |
| Privilege Underwriters Reciprocal Exchange | OFAC | Apparent Ukraine-/Russia-Related Sanctions Regulations violations: White Plains, NY-based luxury insurer collected 38 premium payments and paid a claim on four policies issued to a Panama company (Medallion, Inc.) owned by sanctioned Russian oligarch Viktor Vekselberg after his April 2018 designation. | $466,200 | |
| CoinList Markets LLC | OFAC | Apparent Ukraine-/Russia-Related Sanctions Regulations violations: San Francisco virtual-currency exchange opened 89 accounts for and processed 989 transactions on behalf of users ordinarily resident in Crimea who self-reported "Russia" as their country of residence. | $1,207,830 | |
| Nasdaq, Inc. | OFAC | Apparent ITSR violations: former Armenian subsidiary Nasdaq OMX Armenia OJSC, operator of the Armenian Stock Exchange, knowingly processed 151 trades and settlement transactions involving the OFAC-designated Armenian subsidiary of Iran's state-owned Bank Mellat. | $4,040,923 | |
| Binance Holdings Ltd. | OFAC | OFAC component of the combined settlement: apparent violations of multiple sanctions programs by processing transactions for users in Iran, Syria, Crimea, and other sanctioned jurisdictions. | $968,618,825 | |
| Binance Holdings Ltd.combined | Multi-agency | Combined-agency settlement (DOJ, FinCEN, OFAC, CFTC) for failures to maintain an effective AML program and apparent violations of multiple sanctions programs (Iran, Syria, Crimea, others). | $4,316,126,163 | |
| daVinci Payments | OFAC | Apparent violations involving the issuance of pre-paid reward cards to recipients in Crimea, Cuba, Iran, and Syria due to inadequate sanctions screening. | $206,213 | |
| 3M Company | OFAC | Egregious apparent ITSR violations: Swiss subsidiary 3M (East) AG knowingly sold reflective license-plate sheeting via a German reseller to Bonyad Taavon Naja, an entity controlled by Iran's Law Enforcement Forces, after misrepresenting the end-user to internal trade-compliance counsel. | $9,618,477 | |
| Emigrant Bank | OFAC | Apparent ITSR violations for maintaining a CD account on behalf of two Iran-resident individuals over more than two decades. | $31,868 | |
| Island Pyrochemical Industries Corp. | DDTC | Settled alleged AECA/ITAR violations under ITAR Part 129 involving unauthorized brokering of defense articles with a Chinese counterparty and false statements on license applications. | $850,000 | |
| Construction Specialties Inc. | OFAC | Egregious apparent ITSR violations: New Jersey building-materials company's UAE subsidiary CSME, at its general manager's direction, imported U.S.-origin goods to Dubai and knowingly re-exported them to Iran for a Tehran shopping-mall project, falsifying trade documents to obscure the destination. | $660,954 | |
| VTA Telecom Corporation | BIS | Settled charges for procuring U.S.-origin EAR-controlled items on behalf of Russian aerospace and military end-users without authorization. | $1,865,610 |
Showing the first 50 of 329 actions. Filter to narrow the set.
It isn't just the fine
The bill the headline number doesn't show.
Every settlement above is the visible part of the cost. The obligations that ride with it usually outlive the cash payment and shape how a company sells, hires, and reports for years.
3–5 years
Mandatory external audits
Most consent agreements require an Internal Special Compliance Officer or third-party Special Compliance Official to sit on the program for three to five years. Their reports go directly to the agency. Their fees — typically seven figures annually — sit on the company's balance sheet whether the program improves or not. Self-disclosure can shorten this term, but it almost never disappears.
Statutory debarment
Loss of export privileges
A criminal AECA conviction triggers automatic statutory debarment under the ITAR — three years minimum, no defense exports of any kind. BIS denial orders revoke EAR privileges with similar effect. For prime contractors, the downstream cost is the loss of TAA agreements, foreign sales authorizations, and the customers that depend on them. Reinstatement is discretionary, slow, and conditional.
Public record
The reputational tail
Every consent agreement is published in full on the agency's website, naming officers and conduct. Procurement teams at primes search those agreements before awarding. Underwriters factor them into D&O premiums. Banks reprice credit. Five years on, the action is still the first result for a company name on Google — long after the audit period closes.
Now do the math
A $404.1K median fine. Or a HEXDI seat.
The cheapest hour you'll spend this quarter is the one that tells you which of the rows above describes your program. Run the free scorecard or open a trial to map your exposure against the same standards the agencies above enforce.