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OFAC imposed the $4,677,552 penalty under the Russia Harmful Foreign Activities Sanctions (RuHSR / EO 14024). The factual core: in March 2022, OFAC designated a family member of a Russian oligarch under EO 14024, blocking US-sited real property held by that person in their own name in Atlanta, Georgia. King Holdings LLC purchased the property at public auction in January 2023 — after the blocking order was in force. OFAC issued a cease-and-desist order to King Holdings directing it to stop violating the sanctions prohibitions. Notwithstanding that order, the respondent:
1. Mortgaged the blocked property 2. Renovated it using operational funds 3. Sold it to an unwitting third-party buyer, closing the transaction in violation of the cease-and-desist 4. Certified to OFAC a subpoena response that omitted any mention of the pending sale
OFAC classified the violations as egregious (the respondent had actual knowledge of the sanctions and a specific enforcement warning) and non-self-disclosed (discovered through OFAC investigation, not voluntary reporting), triggering the statutory-maximum methodology under 31 CFR 501 Appendix A. The USD 4,677,552 penalty equals the 2025 inflation-adjusted statutory maximum for individual respondents — a benchmark previously confined to large institutional violators.
below USD 1M; the SB0323 statutory-maximum methodology signals OFAC will seek full individual exposure — not just corporate — where an individual directly controls the violating entity and ignores an explicit cease-and-desist.
corporate penalty against a company also linked to Deripaska's family network). Together they establish a November 2025 enforcement tranche targeting oligarch-family-member conduit structures used to preserve US-real-estate assets post-2022.
2024 Residential Real Estate Rule (requiring beneficial-ownership disclosure on cash purchases). SB0323 demonstrates OFAC's willingness to pursue enforcement against buyers who acquire blocked property through public auction channels, not just direct private transactions.
individual penalties; the statutory-maximum outcome here — under a Trump-administration OFAC — reflects continuity of Russia-sanctions enforcement architecture despite broader geopolitical signals, at least in the civil-penalty track.
has fully settled or remains in litigation.
constitutes a potential obstruction/perjury exposure separate from the civil-penalty track.
other Russia-EO-14024-property-adjacent enforcement cases currently in the OFAC pipeline.