The U.S. Treasury’s Office of Foreign Assets Control (OFAC) has issued a $216 million civil penalty—the maximum allowed by law—against a U.S.-based company for violating sanctions related to Russia and Ukraine, as well as for noncompliance with an OFAC subpoena.
The agency cited “willful” violations that enabled a sanctioned Russian national to access the U.S. financial system, flagging it as a serious breach of federal compliance standards. While the company had no prior OFAC penalties in the last five years, the agency determined that the severity of the offense warranted no reduction in the fine.
This action underscores the critical importance of due diligence, particularly for service providers deemed “gatekeepers” to the financial system—such as attorneys, accountants, investment advisors, and corporate service providers. OFAC reiterated the growing risk that sanctioned individuals or entities may exploit these professionals to bypass enforcement mechanisms.
OFAC encourages firms operating in global finance, logistics, and professional services to proactively identify and mitigate exposure to sanctioned parties. Sobel advises all clients engaged in international transactions to review internal controls, ensure compliance systems are up to date, and train relevant personnel on evolving U.S. sanctions risks.