US Treasury imposes record $508 million fine on British American Tobacco for violating North Korea and WMD sanctions

The US Treasury’s Office of Foreign Assets Control (OFAC) announced a $508 million settlement agreement with British American Tobacco p.l.c. (BAT), which is the largest ever with a non-financial institution. This settlement resolved BAT’s apparent violations of US sanctions on North Korea and proliferators of weapons of mass destruction. OFAC’s investigation found that BAT engaged in a seven-year conspiracy from 2009 to 2016 to send over $250 million in profits from a North Korean joint venture through US financial institutions by relying on designated North Korean banks and a variety of intermediaries. BAT has agreed to pay the penalty and significant compliance commitments and investments for the next five years.